ML20236M899

Forwards Ltr Sent to American Society for Nondestructive Testing,Inc Informing That NRC Has Completed Evaluation of Industrial Radiography Radiation Safety Personnel Certification Program

ML20236M899
Person / Time
Issue date:	07/07/1998
From:	Combs F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Collins S AFFILIATION NOT ASSIGNED
References
NUDOCS 9807140312
Download: ML20236M899 (4)

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UNITED STATES g

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t WASHINGTON, D.c. 20555-0001 l

.m.p July 7, 1998 Steven C. Collins, Chairperson Conference of Radiation Control Program Directors, Inc.

205 Capital Avenue Frankfort, KY 40601

Dear Mr. Collins:

Enclosed is a copy of a letter recently sent to the American Society for Nondestructive Testing, inc. (ASNT) informing ASNT that the Nuclear Regulatory Commission (NRC) had completed its evaluation of ASNT's Industrial Radiography Radiation Safety Personnel (IRRSP) certification program and found that the program meets criteria established in 10 CFR Part 34, Appendix A, Our letter also informed ASNT that it is recognized as a Certifying Entity, i.e., an Independent Certifying Organization, and that individuals wishing to act as radiographer who are certified in isotope radiography through the IRRSP program will meet the certification requirement specified in 10 CFR 34.43(a)(1).

A Federa/ Register notice (enclosed) announcing NRC's finding concerning ASNT's IRRSP program was published June 1'7,1998. The notice also identifies those Agreement States which currently administer certification programs as certifying entities.

In order to draw on the experience and expertise of some of the Agreement States in administering certification programs, we used a team approach to review the ASNT application.

We are pleased that the evaluation of ASNT's IRRSP submission as a cooperative effort involving NRC, the Agreement States, and the Conference of Radiation Control Program Directors, Inc. (CRCPD) was very successful. As noted in Mr. Thompson's October 17,1997, letter to you, the working group tasked with reviewing ASNT's submission, used the document entitled, " Recommendations for Reviewing an Application to Become a Certifying Entity" developed by the CRCPD's G-34 Committee as the basis for developing the review criteria.

NRC recognizes the importance of maintaining a cooperative approach, and intends to continue such an approach with the CRCPD, the Organization of Agreement States, and industry in working toward a nationwide industrial radiography certification program. With this idea in

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mind, we believe a meeting or workshop with the certifying entities to discuss communication,

[f cooperation, information exchange, and oversight activities would be of tremendous value. We also believe that the CRCPD is suitably positioned to facilitate this process and NRC would be g \\ g )t

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pleased to participate. Such a meeting could augment the considerable work already achieved by the CRCPD G-34 Committee. If a meeting would be of interest, please contact Larry Camper at (301) 415-7231 so that we may discuss arrangements.

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July 9, 1998 4

2 Steven C. Collins, Chairperson During our review of the ASNT application, a meaningfulissue surfaced. Specifically, several working group members strongly supported a recommendation that a certifying entity contact l

the licensing authorities as necessary, to confirm that training courses documented by an l

applicant were in fact approved. However, while we may agree in principle with those members, NRC did not have a regulatory basis in Appendix A to insist the suggested procedures be incorporated. In our May 15,1998, letter to ASNT we indicated our belief that such procedures are appropriate, and would lend consistency with the practice of the States which are currently certifying radiographer. Subsequently, in a letter dated June 14,1998, CRCPD raised this issue with ASNT, indicating the current state certifying entities would not consider the ASNT training certification process as squivalent or comparable. As a result, the state certifying entities will not reciprocally recognize ASNT certification because it does not include confirmation of training. We suggest CRCPD consider including this issue in the cited meeting / workshop agenda.

Sincerely, Originial signed by F. Combs Frederick C. Combs, Acting Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards

Enclosures:

1. Ltr dtd 5/15/98

2. FRN dtd 6/17/98 Distribution:

NRC Central File IMNS r/f NMSS r/f Jim Myers, OSP NMSS Dir Off r/f PDR X YES NO DOCUMENT NAME:G:fc-crcpd.jbc OFC MSB*

MSB*

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NAME BCarrico/LL LCamper h

Not DATE 7/1/98 7/1/98 7/

/98 7/ 7 /98 OFFICIAL RECORD COPY

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2 Steven C. Collins, Chairperson l

During our review of the ASNT application, a meaningfulissue surfaced. Specially, several working group members strongly supported a recommendation that a certifying entity contact the licensing authorities as necessary, to confirm that training courses document by an applicant were in fact approved. However, while we may agree in principle wit hose i

members, NRC did not have a regulatory basis in Appendix A to insist the s gested procedures be incorporated. In our May 15,1998, letter to ASNT we indi ed our belief that such procedures are appropriate, and would lend consistency with the ractice of the States which are currently certifying radiographer. Subsequently, in a le r dated June 14,1998, i

- CRCPD raised this issue with ASNT, indicating the current state ertifying entities would not consider the ASNT training certification process as equivalen r comparable. As a result, the I

state certifying entities will not reciprocally recognize ASNT ratification because it does net include confirmation of training. We suggest CRCPD co ider including this issue in the cited meeting / workshop agenda.

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rely, Frederick C. Combs, Acting Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards

Enclosure:

Ltr dtd 5/15/98 FRN did 6/17/9 1

Distribution:

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l Steven C. Collins, Chairperson During our review of the ASNT application, a meaningfulissue surfaced. Specifically, several working group members strongly supported a recommendation that a certifying entity contact the licensing authorities as necessary, to confirm that training courses documented by an l

applicant were in fact approved. However, while we may agree in principle with those l

' members, NRC did not have a regulatory basis in Appendix A to insist the suggested procedures be incorporated. In our May 15,1998, letter to ASNT we indicated our belief that such procedures are appropriate, and would tend consistency with the practice of the States t

which are currently certifying radiographer. Subsequently, in a letter dated June 14,1998, CRCPD raised this issue with ASNT, indicating the current state certifying entities would not consider the ASNT training certification process as equivalent or comparable. As a result, the state certifying entities will not reciprocally recognize ASNT certification because it does not include confirmation of training. We suggest CRCPD consider including this issue in the cited meeting / workshop agenda.

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Sincerlely,

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.J Fred ick C. Combs, Acting Director Division of industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards

Enclosures:

1. Ltr dtd 5/15/9

2. FRN dtd 6/17/98

[fa arog t UNITED STATES g

g NUCLEAR REGULATORY COMMISSION

'f WASHINGTON. D C. 2055M001 og **../

May 15, 1998 Robert K. Windsor Executive Director The American Society for Nondestructive Testing, Inc.

1711 Arlingate Lane P.O. Box 28518 Columbus, OH 43228-0518

Dear Mr. Windsor:

The American Society for Nondestructive Testing, Inc. (ASNT) is hereby recognized as a Certifying Entity, i.e., an Independent Certifying Organization (ICO) based on our finding that your Industrial Radiography Radiation Safety Personnel (IRRSP) certification program meets the criteria established in 10 CFR Part 34, Appendix A. Individuals wishing to act as radiographer who are certified in isotope radiography through the IRRSP program are deemed to meet the certification requirement specified in 10 CFR 34.43(a)(1). This finding is based on your April 23, 1997, submission and your letters dated January 5,1998, February 12,1998, March 12,1998, and April 17,1998, which provided additional information and clarification for several items in the initial submission.

One residual issue requires attention to complete your application; however, it is not essential to authorize ASNT as an ICO. Specifically, in your April 17,1998, letter, you indicate you will revise your program to further clarify and include more detailed procedures for processing requests for reinstatement. However, you note that because such procedures must be approved by certain ASNT governing bodies, the modified procedures will not be available until after the Summer meetings in July 1998. Based on your commitment to develop these procedures, we find this area acceptable. Once completed, these procedures are to be provided to NRC for review to ensure their adequacy and to complete the application file.

Completion of a formal training program is one of the critical elements for certification. While Appendix A of 10 CFR Part 34 does not specify that certifying organizations contact the cognizant licensing authority to confirm that the training courses cited by an applicant have been approved, we strongly suggest that ASNT incorporate procedures as suggested in our letters of March 9 and April 13,1998. We believe that such procedures are appropriate, and would lend consistency with the practice of the States which are certifying radiographer.

Your April 17,1998, letter also inquires if NRC would consider extending the deadline for implementing certification. Given that a year remains before the final deadline, we do ic*

believe there is a need to consider extending the deadline at this time. However, you should bc aware you always have the opportunity to petition the NRC for a rule change pursuant to 10 CFR 2.802.

4p0gp/dogg-ENCLOSURE 1

Robert K. Windsor, Executive Director 2

Please be aware that should you decide to revise procedures which form the underlying basis for NRC's approval of the IRRSP program applicable to 10 CFR Part 34, Appendix A, such revisions need to be submitted and approved by NRC prior to implementation. Revisions which are only administrative in nature do not need to be submitted.

I We want to commend ASNT on the extraordinary effort ASNT clearly devoted to developing its j

IRRSP program and the application to be an ICO. Throughout the lengthy process leading to 1

. mandatory certification, ASNT has exhibited the highest level of professionalism and sincere l

interest in protecting radiographer and members of the general public. Your tenacity is commendable. We are pleased to reach a successful conclusion and look forward to a continuing interaction with ASNT to further ensure public health and safety in industrial radiography.

Sincere r

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Don d of, Direct r Divisten of ustrial and Medical i

Nuclear Safety Office of Nuclear Material Safety and Safeguards 1

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Fedvral Register /Vol. 63, No.116/ Wednesday, June17,1998/ Rules and Regulations 32071 IX. Backfit Analys S NUCLEAR REGULATORY parenthetical sentence in 10 CFR The NRC has dete mined that tile COMMISSION 34.43(a)(1) states, "An independent

'oacklit rule does not pply to this final organization that would like to be ruleznd, therefore, a ackfit analysis is 10 CFR Part 34 not rtquired for this fi tal rule because recognized as a certify ng entity shall these mendments do iot mvolve any Radiographer Certification-Certifying 1 ar A7a erial Safe Y a d Entitles provis ons that would : pose backfit's Safeguards, U.S. Nuclear Regulatory as defi ed in 10 CFR C pterI.

AGEP CY: U.S. Nuclear Regulatory Commission *

• " Part I of Commission.

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Appendix A to Part 34 provides the X. Sma 1 Business Regul tory Enforce ent Fairnas At ACTION: Notice of certifying entities.

requirements for an independent ce tifymg organization, and only applies In acc rdance with the mall

SUMMARY

The U.S. Nuclear Regulatory to organizations other than the Business egulatory Enfor ement Commission (NRC) staff has completed Agreement States. Parts !! and 111 of Fairness t of 1996, the N 'C has its evaluation of a request from the Appendix A to Part 34 provide the determine that this action not a American Society for Nondestructive requirements for certification programs major rule - d has verified t is Testing, Inc. (ASNT) to be recognized as and written examinations for a determinate with the Offic of a Certifying Entity, i.e., an Independent certifying entity, and includes the Information - d Regulatory A fairs of Certifying Organization. The NRC staff Agreement States.10 CFR Part 34 OMB.

found that ASNT's Industrial Appendix A does not impose new Radiography Radiation Safety Personnel requirements on licensees.

List of Subjects 'n to CFR Part 2 (IRRSP) certification program meets the To be recognized as an independent By roduct ma erial, Criminal criteria established in the NRC's certifying organization, the organization penafties, Labell, Nuclear mat -lais, regulations governing radiographic should be a national society or Radiation protecti n Reporting a d operations. Therefore, the NRC association involved in setting national ecordkeeping req irements.

recognizes ASNT as a Certifying Entity standards of practice for mdustrial For the reasons s t out in the and individuals wishing to act as radiography or non-destructive testing.

p eamble and unde the authority c the radiographer who are certified in An acceptable certification program A mic Energy Act f 1954, as amen ed; isotope radiography through the IRRSP w uld require tralmng m the subiects th Energy Reorgani 1 tion Act of 19, program meet the certification listed in 10 CFR 34.43(g), completton of as ended; and 5 U '.C. 553; the N requirement specified in the regulations.. a written and practical examination, and is a opting the follow ng amendments ASNT joins the following Agreement requir,e a minimum period of on the-}ob to 1 CFR Part 32.

States as certifying entities: Georgia,

'yn Erfl 1997, NRC received a Ilhnois, Iowa, Louisiana, Nevada North PAR 32-SPEOlFIC MESTIC Dakota, and Texas.

submission from ASNT requesting LICE SES TO MANUF CTURE OR TRAN FER CERTAIN I EMS FOR FURTHER INFORMATION CONTACT: J.

E CONT INING BYPROD JCT MATERIAL Bruce Carrico, U.S. Nucleat Regulatory 8 "8*

Commission, Office of Nuclear Material y[ca"i P

1. Th authority citath n for Part 32 Safety and Safeguards. MS T8F5, p gm low continu s to read as foll vs:

Washmgton, DC 20555, telephone (301) the program complies with 10 CFR Part 34, Appendix A criteria. A " team" E

OR A N n May evalu ting subm ss

n. The team or 93,9 3

4, as am 3 S 2111. 2201 2232,2233); sec. t,88 Stat.

28,1997 (62 FR 28948), NRC published

" working group" was composed of three 1242, as a 'nded (4 2 U.S C.

41).

a final rule in the Federal Register that NRC staff members, two Agreement

2. In $ 3.14, paragraph ( )is revised revised the regulations applicable to to read as f Ilows:

industrial radiography,10 CFR Part 34.

State representatives from certifying This overall revision of 10 CFR Part 34 states,and an Agreement State

$ 32.14 ce in items containi introduced several new requirements.

representative from a non-certifying state. An expert in the NRC's Office of byproduct m erial; requireme afor One of these new requirements, Nuclear Reactor Jtegulation, Division of licznse to app or inittelly trans er.

specified in 10 CFR 34.43(a)(1),

Reactor Controls and Human Factors.

provides that licensees may not permit Human Factors Assessment Branch also (d) The Co nission determi es that:

any individual to act as a radiographer (1) The bypr duct material is roperly until the individual "is certified through those portions of the submissionass i

contained in th product under he most a radiographer certification program by applicable to examination development.

I severe conditio s that are likely o be a certifying entity in accordance with The working group completed its encountered in ormal use and the criteria specified in Appendix A of evaluation of the submission in April halgdling.

this part (34)i" This requirement 1998.

(2) For automo ile lock illumin tors, becomes effective June 27,1999.

In a letter dated May 15,1998, NRC the product has b en subjected to nd As defined in 10 CFR Part 34, informed ASNT ofits finding that meets the require ents of the prot > type " Certifying Entity means an ASNT's IRRSP certification program met tests p scribed by 32.40, Schedu e A.

Independent certifying organization the criteria established in 10 CFR Part Dated Rockville, taryland, this 9tLda}

meeting the requirements in Appendix 34 Appendix A, that ASNT was

. fJune,1 98.

A of this part or an Agreement State recognized as a Certifying Entity.

l For the uclear Reg 'atory Cornm.iss.

meeting the requirements in Appendix Individuals wishing to act as John C. Ho e, A Parts 11 and lll of this part." An radiographer who are certified in l

Secretaryof.e Commis on.

independent certifying organization is isotopo radiography through the IRRSP defined as " *

• an independent program will meet the certification

[FR Doc. 98-1 014 Filed 16-98;8:45 am organization that meets all of the criteria requirement specified in 10 CFR sumo coos 7sso-op of Appendix A to this part." A 34.43(a)(1).

ENCLOSURE 2

329 2 Federal Register /Vol. 63 No.116/ Wednesday, June 17,1998/ Rules and Regulations 1

The following Agreement States also th Rules Docket weekdays, except helicopter with the Arriel 2S1 engine administer certification programs as Fe tal holidays, between 7:30 a.m.

d installation will have the following Certifying Entities: Georgia, Illinois, 4:00

.m.

power ratings: 30-second One-Engine-lowa, Louisiana, Nevada, North Dakota, FOR F THER INFORMATION CONTACT:

Inoperative (OEI),2 minute OEI, and Texas. Individuals wishing to act as Scott I rn, FAA, Rotorcraft Directorate, Continuous OEI,30 minute, Takeoff, radiographer who are certified in Rotorcra Standards Staff, Fort Worth, nd Maximum Continuous ratings.

isotope radiography through one of Texas 761 3-0110, telephone (817)

The current rotorcraft maximum these state programs will meet the 222-5125, x (817) 222-5961.

C ' tinuous ratmg is at the same torque certification requirement specified in 10 SUPPLEMENTS Y INFORMATION: The FAA and EM limits as the proposed 30-CFR 34.43(a)(1).

has determine that notice and minu ratm As a result, the FAA has determ ed at compliance with the Dated at Rockville, Maryland this 9th day opportunity for rior ublic comment d

ve s tem hereon are impra ica le because these

[q"uire of June,1998.

es For the Nuclear Regulatory Commission.

procedures would gnificantly delay has not been ffected by this new rating Iorry W. Camper, Chief, Afaterials Safety issuance of the appt val design and application. In ddition, all the power Branch. Division ofIndustrial and Afedical thus ~ delivery of the a ected hehcopter.

Nuclear Safety. Office of Nuclaar Afatecial Th,e FAA therefore fin that good cause parameter limits nd ranges for the 30-Safety and Safeguards.

exists for making these s ecial minute power coi ide with the existing instrument marking or the takeoff lFR Doc. 98-16135 Filed 6-16-98; 8:45 am]

conditions effective upon ssuance.

rating. Therefore, thes

arkings, a Luwo code 76eo-41-P Comments invited applied to the new 30-m ute power, Interested ersons are invi d to have been found to comply vith the P

DE ARTMENT OF TRANSPORTATION bmit such written data, vies s, or part 29 re1ulrements.

The app 1 cable airworthiness uments as they may desire, requirements do not contain a 30-Fede i Aviation Administration Co, unications should identif the minute power rating definition and do regul 'ory docket and be submitt in not contain adequate or appropriate 14 CFR arts 21 and 29 duplict e to the address specified ove-safety standards for the type All com unications received on or certification of this new and unusual (Docket No. WOO 4; Special Conditions No.

39-004-SC]

before the losmg date for comments engine rating. Due to increased Ni (gas will be cons ered.The special turbine speed) and T (turbine outlet 3

Special Condi ns: Sikorsky Aircraft conditions m be changed in light of temperature) limits for this new rating, i

Corporation, Mo l S76C; Application the comments r ceived. All comments s compared to the existing continuous of Rated 30-Minut ower received will be 'allable in the Rules r ting, airworthiness requirements must Docket for examin ion by interested be eveloped for powerplant cooling AGENCY: Federal Avia. n persons, both before nd after the and erational limitations.

Admmistration (FAA),

T closing date for comm ts. A report Addit' nally, for use of the 30-minute l

ACTION: Final special con ions; request summarizing each subst tive public power ting, the engine manufacturer I

for cornments.

contact with FAA person 1 concerning has estab 'sbed a new method to this rulemaking will be file in the determine e engine overhaul time.

3,,"d fo e b'o,e{yP, a docket. Commenters wishing

.e FAA to The new me, od accelerates the engine

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sam

},

acknowledge receipt of their co. ments hours time-in-ice when the 30-heh opter. This helicopter wtgav submitted in response to this spe 'al minute rating is sed. For the Sikorsky nove or unusual design feature condition must include a self.addr sed. Model S76C helic ter, the pilot is 1

associ ted with a new rated 30-mm.ute stamped postcard on which the required to record th 30-minute rating power. he applicable airworthiness llowing statement is made:

usage, since no means f automatically regulati is ao not contam adequate or

' 'emments to Docket No. SWOO4." The counting or recording is ovided. As a appropri e safety standards for this po card will be date stamped and sult of the additional wo load to the new rated 0 minute power.These 7

ret ed to the commenter.

special con tions contain the pi t, the FAA has determin. that a additional sa ty standards that the Backgr und two-ilot crew is necessary to eet the Administrator nsiders necessary to On Nos mber 19,1997, Sikorsky P

29-establish a level f safety equivalent to Aircraft Co oration applied for a that established b the existing change to Ty. Certificate (TC) No.

Type Certi ation Basis airworthiness stan ds-H1NE for use o a rated 30-minute Under the visions of 14 CFR DATES: The effective te of these power on the M el S76C helicopter.

21.101. SikoEkircraft Corporation special conditions is J 17,1998.

The Sikorsky Mod S76C is a transport must show that th Model S76C Comments must be receis d on or category A and B rot craft powered by helicopter with the. rriel 2S1 engine before July 17,1998.

two Turbomeca Arriel S1 engines with installation meets the plicable ADDRESSES: Comments on th e special e maximum gross weigh i11,700 provisions of the reguia 'ons in effect on pounds $1ew rated 30-minute the date of the applicatio or tha conditions may be mailed in d licate to: Federal Aviation Administrate n This ower is applicable provisions of th regulations (FAA), Office of the Regional Coun. 1, intended for periods of use u to 30 as referenced in TC Number 11NE. The Attention: Rules Docket No. SWOO4, minutes at any time after takeo during regulations incorporated by re rence in j

2601 Meacham Blvd., Room 663. Fort a flight performing search and r cue the TC are commonly referred t as the i

Worth. Texas 76137; or delivered in missions. However, this rating is so

" original type certification basis. The duplicate to the Office of the Regional itable for other missions that req 're regulations incorporated by refere e in Counsel at the above address.

in reased rotorcraft hovering capabih v TC Number HINE are as follows:

uration than the current ratings Part 29, effective February 1,1965,'

Comments must be marked Docket No.

an SWOO4. Comments may be inspected in allow. The Sikorsky Model S76C plus Amendments 29-1 through 29-11;

l Steven Cl Collinc Jill Upt, Ph.D., Chairperson Conference of Radiation Control Program Directors, Inc.

L 205 Capital Avenue Frankfort, KY 40601

Dear Mr. Collins Or. Uptl:

Enclosed is a copy of a letter recently sent to the American Society for Nondestructive Testing, Inc. (ASNT) informing ASNT that the Nuclear Regulatory Commission had completed its

- evaluation of ASNT's Industrial Radiography Radiation Safety Personnel (IRRSP) certification program and found that the program meets criteria established in 10 CFR Part ?4. Appendix A, Our letter also informed ASNT that it is recognized as a Certifying Entity, i.e., an Independent l

Certifying Organization, and that individuals wishing to act as radiographer who are certified in l

lsotope radiography through the IRRSP program will meet the certification requirement

. specified in 10 CFR 34.43(a)(1).

A Federal Register notice (enclosed) announcing NRC's finding concerning ASNT's IRRSP l

program wasjc spd to bc published June.17l1998-seen The notice will also identifies j

identify those Agreement States which currently administer certification programs as Certifying l

Entities.

In order to draw on the experience and expertise of some of the Agreement States in administering certification programs, we used a team approach to review the ASNT application.

l We are pleased that the evaluation of ASNT's IRRSP submission as a cooperative effort involving NRC, the Agreement States, and the Conference of Radiation Control Program Directors, Inc. (CRCPD) was very successful. As noted in Mr. Thompson's October 17,1997, letter to you, the working group tasked with reviewing ASNT's submission, used the document entitled, " Recommendations for Reviewing an Application to Become a Certifying Entity" developed by the CRCPD's G-34 Committee as the basis for in developing the review criteria.

NRC recognizes the importance of maintaining a cooperative approach, and intends to continue such an approach with the CRCPD, the Organization of Agreement States, and industry in working toward a nationwide industrial radiography certification program. With this idea in mind, we believe a meeting or workshop with the certifying entities to discuss communication, cooperation, information exchange, and oversight activities would be of tremendous value. We also believe that the CRCPD is suitably positioned to facilitate this process and NRC would be pleased to participate. Such a meeting could augment the considerable work already achieved by the CRCPD G-34 Committee.f if a. meeting would be;of interest, please contact Larry Camper at (301) 415-7231.so that we may discuss arrangements.

During our review of the ASNT application, a meaningfulissue surfaced. Specifically, several working group members strongly supported a recommendation that a Certifying Entity contact the licensing authorities as necessary, to confirm that training courses documented by an aoplicant were in fact approved. However, while we may agree in principle with those members, NRC did not have a regulatory basis in Appendix A to insist the suggested procedures be incorporated. In our May 15,1998, letter to ASNT we indicated our belief that such procedures are appropriate, and would lend consistency with the practice of the States which are currently certifying radiographer. We suggest CRCPD consider including this issue-in the meeting / workshop agenda.

l l

i y

Sincerely, 1

Frederick C.' Combs, Acting Director Division of Industrial and Medical Nuclear Safety -

Office of Nuclear Material Safety l

and Safeguards -

l

Enclosures:

Ltr dtd 5/15/98

t. FRN dtd_6/17/98

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Conf renc3 of Radiation Control Program Directors, Inc.

I Office of Executive Director

• 205 Capital Avenue

• Frankfort, KY 40601 Phone (502) 227-4543. Fox (502) 227-7862

[L i

June 4,1998 Robert K. Windsor Executive Director The American Society for Nondestructive Testing, Inc.

1711 Arlingate Lane P.O. Box 28518 Columbus, Ohio 43228-0518

Dear Mr. Windsor:

We would like to congratulate you and the Board of the American Society for Nondestructive Testing, Inc. (ASNT) for the recent recognition as an industrial radiographer Independent Certifying Organization by the U.S. Nuclear Regulatory Commission (NRC). In the interest of continued cooperation among industrial radiography cenifying entities, the Conference of Radiation Control Program Directors, Inc. (CRCPD) offers the following additional information concerning the May 15,1998, letter fromNRC to ASNT recognizing ASNT as an Independent Certifying Organization.

In the recognition letter, the NRC notes that, even though 10 CFR 34, Appendix A does not specify that certifying organizations contact the cognizant licensing authority to confirm that the training courses cited by the applicant have been accepted or approved, the NRC strongly suggests that ASNT incorporate procedures to verify such training.

Over the years, the state certifiers have incorporated language in their respective regulations that allows reciprocal recognition of individual industrial radiographer' certification if the certifications are current, valid, and issued by an entity with an equivalent cenification program. This concept was added to the various regulations to facilitate nationwide recognition of the certification issued by the various entities thus eliminating the need for industrial radiographer to possess multiple certifications. The CRCPD, through its G-34 Committee on Industrial Radiography, has worked diligently with the states over the years to encourage this kind of consistency in regulations and certification programs. In fact, the CRCPD has incorporated similar language in the upcoming suggested state regulations conceming industrial radiography. The suggested state regulations serve as models that radiation control programs use in developing and modifying their state regulations.

l 1

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A Partnership Dedicated tc Radiation Protection

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Roben K. Windsor June 4,1998 Page Two On May 18,1998, the current state certifying entities (Georgia, Illinois, Iowa. Louisiana.

North Dakota, and Texas) discussed the issue of training verification. These states have significant

/

concerns about ASNT omitting verification of training in its certification program. Your program will not be considered equivalent or comparable to that of the state certifying entities. Further, the state certifying entities will not reciprocally recognize any ASNT cenification issued under the certification program approved by the NRC on May 15,1998, that does not include confirmation of training as described in the second paragraph above.

We wish to continue the spirit of cooperation that our organizations have had in the past, so we are making you aware of our concerns in as timely a manner as possible. Should you wish to discuss this issue funher, please contact Ms. Jan Endahl, Chair of our G-34 Committee on Industrial Radiography, at (512) 834-6688 or E-mail address: Jan.Endahl@tdh. state.tx.us S ncerely,

$d N#

Steven C. Collins CRCPD Chairperson cc:

CRCPD Board of Directors Don Cool, NRC Chuck Hardin, CRCPD Don Flater, Iowa Bill Spell, Louisiana Dana Mount, Nonh Dakota Richard Ratliff, Texas Steve Black l

l

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