U.S. Nuclear Regulatory Commission

Technical Assistance Request Concerning Posting per 10 CFR 34.42 and Surveys per 10 CFR 20.201

HPPOS-296 PDR-9306220099

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

welds:

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

Applicability: Radiography