U.S. Nuclear Regulatory Commission
Technical Assistance Request Concerning Posting per 10 CFR 34.42 and Surveys per 10 CFR 20.201
Title: Technical Assistance Request Concerning Posting per
10 CFR 34.42 and Surveys per 10 CFR 20.201
See the memorandum from J. E. Glenn to R. Cooper dated July
7, 1990. This memo responds to a technical request from
Region I, dated May 18, 1990, on the above subjects. In
general, the staff may by 10 CFR 20.501 [or, at present, 10
CFR 20.2301] and 10 CFR 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.
Provided below are answers to specific questions regarding
posting and surveys when performing radiography on pipeline
1. Posting of radiation areas 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?
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.
2. Performance of radiation area surveys per 10 CFR
20.201 [or, at present, 10 CFR 20.1501]: How often does
one need to survey to confirm the radiation and high
radiation areas when performing radiography along a
pipeline where weld exposure geometries are essentially the
same but shielding provided by adjacent terrain varies?
The licensee is required to make an evaluation of radiation
hazard any time the conditions of the radiation exposure
changes. Accordingly, even though the weld-to-weld exposure
geometries 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.
Regulatory references: 10 CFR 20.201, 10 CFR 20.501, 10
CFR 20.1501, 10 CFR 20.2301, 10 CFR 34.42, 10 CFR 34.51
Subject codes: 4.7, 7.1