ML20044A816
| ML20044A816 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1990 |
| From: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20044A817 | List: |
| References | |
| HPPOS-296, NUDOCS 9007130160 | |
| Download: ML20044A816 (2) | |
Text
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UNITED STATES NUCLEAR PEGULATORY COMMISSION
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MEMORANDUM FOR:
Richard Cooper, Deputy Director Division of Radiation Safety and Safeguards, RI FROM:
John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
TECHNICAL ASSISTANCE RE00EST CONCERNING POSTING PER 10 CFR PART 34.42 AND SURVEY'S PER 10 CFR PART 20.201 This is in reference to your Technical Assistance Request dated May 18, 1990, on the above subjects.
In general, the staff may by 10 CFR 20.501 and 34.51 consider any application for an exemption to the regulations in 10 CFR Part 20 or 10 CFR Part 34 if it determines the exemption is (1) authorized by law, (2) will not result in undue hazard to life or property, and (3) the applicant has submitted sufficient justification. However, the staff is not required to grant an exemption request.
Regarding your specific quesition:
Q.
1.
Posting per 10 CFR 34.42 Does NRC consider exceptions to the posting requirements in such practical field situations as thick brush or woods immediately adjacent to the radiography operation, or radiography operations that are adjacent to a heavily-travelled highway? Can dirt from the pipe ditch be used as a partial shield, or can the ditch itself be used as a barrier preventing access to the radiation area in lieu of posting?
A.
1.
The regulation clearly requires that areas in which radiography is being performed be conspicuously posted. That is, all potential pathways to radiation and high radiation areas must contain the appropriate posting.
Exemptions have not been made for wooded or thick brush areas, ditches, or heavily travelled highways in the past.
The convenience or inconvenience of the posting is not a sufficient criterion alone to grant an exemption.
Q.
2.
Performance of radiation area surveys per 10 CFR 20.201.
How often does one need to survey to confirm the radiation and high radiation areas when performing radiography along a pipeline where j
weld exposure geometries are essentially the same but shielding provided by adjacent terrain varies.
A.
The licensee is required to make an evaluation of radiation hazard any time the conditions of the radiation exposure changes.
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JUL 0 71990 Richard Cooper Accordingly, even though the weld to weld exposure geometrics are essentially the same, if the shielding provided by adjacent terrain varies, a new survey / evaluation is required.
Note that a measurement is not necessarily required in order to make an evaluation.
If you have any additional questions on the matter, you may contact Michael A.
4 Lamastra directly at (FTS) 492-3416.
John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS DISTRIBUTION IMAB-32 NM55 r/f NRC File Center TAR r/f JEGlenn RECunningham GSjoblom IMNS Central File PCVacca LHBettenhausen, RI WECline, RII BSMallett, RIII RJPate, RV MShanbacky, RI JKinneman, RI JWhite, RI CHosey, RII GMMcCann, RIII BRiedlinger, RV SLBaggett, IMAB MLamastra RFonner, OGC EMcAlpine, RII ABBeach, RIV VLMiller, GPA/SP WFisher, RIV JRicci, AEOD/TTC CCain, RIV LWCamper, IMAB r
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