Continuous Coverage

[Ray Meyers]

Can anyone tell me of a written guidance or requirement that tells an RWP writer or Radiological Engineer when to require continuous coverage as opposed to intermittent coverage?

[Already Gone]

First, you go to the site's procedures.  There should be ones covering both job coverage and RWP writing.

Failing that, you might consider writing such a procedure.  Just seems like a good idea to me.  It ought to cover at least the obvious situations like:
Potential to release radioactive material from the RCA
Potential to exceed administrative dose guidelines or RWP limits
Potential to expose other workers (those not on the RWP or unmonitored personnel) to dose rates, contamination levels, or airborne concentrations which exceed those specified by their RWP's
Potential to create an unmonitored concentration of airborne activity above the DAC
Potential to cause skin contamination or external exposure to a level which would result in a measurable SDE or CDE
Potential to create radiation, contamination, or airborne levels which exceed the posting levels for the area
Entry into an area with unknown radiation levels
Breach of systems with high or unknown internal radiation or contamination levels
Manipulation or removal of temporary or permanent shielding
Handling irradiated fuel or highly irradiated components in the reactor cavity or spent fuel pool
Removal of equipment from the cavity or SFP
Work involving non-radiological safety and health hazards which may interfere with radiation protection or compound the hazards of radiation exposure
Entry into the Containment Building or Drywell when the reactor is critical
Emergency response operations inside the RCA (firefighting, EMS, response to a plant or system failure, etc.)
Entry into the RCA by workers not qualified as Radiation Workers
Removal of material or equipment from a RCA
Transfer of radioactive material from one RCA to another

Gee, it's funny what a guy can remember after eight years of not swinging a meter
If you do write that procedure, I wouldn't refuse a consultation fee should you wish to offer one.

[Already Gone]

What's a meter?  Oh, I remember 100 cm!  I guess your memory is better than mine Troy.

It's either that or the notation on the sheet music that tells you how fast to play.

Seriously mutant, cut me some slack.  You don't think I gave a straight-forward answer?!  It ought to be pretty plain, and I don't know how to be more straightforward.  You ALWAYS go to the procedure.  I'm giving Ray the benefit of the doubt here.  Assuming that he really does not know where to find written guidance to perform this task, one has to point him toward the place where you go to get written guidance -- the procedure.

Yet, one must also acknowledge the reality that many procedures can be vague.  Sometimes they are intentionally vague in order to allow professionals to exercise the judgement that makes them professionals in the first place.  Yes, even in the tightassed nuclear industry there are times when you just have to rely on what you know.  If you don't know, you ask.  Ray asked, and I gave him 17 criteria that seem to be pretty reasonable to me.  If you have any more, feel free to chip in with a few.

In fact, I just thought of a couple more:
Work requiring a supplied air respirator or SCBA
Work which requires time-keeping or telemetry to monitor exposure
Diving operations in the SFP, cavity, or contaminated tanks or vessels
Entry into VHRA's
Work with unshielded neutron sources
Work with potential unplanned criticality or reactivity excursions (this is more likely in DOE type facilities)

If you don't like the list, I can boil it down for you into a simple statement.  Continuous coverage is required when the RP technician's knowledge and guidance can be the factor preventing a radiological incident at any point in the work.
Depending on the procedure, it should be possible to switch from continuous to intermittent coverage for different phases or steps of the job.  For example, you could require continuous for a valve breach and intermittent for the rest of the job once the survey establishes that conditions are acceptable to relax coverage.  But there I go again back to the procedure.  You just can't avoid the procedures, can you?

[Nuclear NASCAR]

....  But there I go again back to the procedure.  You just can't avoid the procedures, can you?

Not these days that's for certain.  With the emphasis on Procedure (& Written Instruction) Use & Adherence it could be the kiss of death on a career to ignore their importance.

[SloGlo]

Can anyone tell me of a written guidance or requirement that tells an RWP writer or Radiological Engineer when to require continuous coverage as opposed to intermittent coverage?

try googlling "continuous radiological coverage of workers". 

first couple of items are d.o.e. sited.

good luck.

[redline]

If you're talking commercial, a sites tech specs will dictate what the site has committed to do in order to comply with CFR's. Procedures should be written to comply with the tech spec. But when you have an "event" only the tech spec really matters to NRC. INPO on the other hand seeks perfection and AFI's get harder to rebound from every year. Generally the older a site is the more forgiving the tech spec.

[105KW]

Can anyone tell me of a written guidance or requirement that tells an RWP writer or Radiological Engineer when to require continuous coverage as opposed to intermittent coverage?

Ray,

I know this doesn't answer your question, but you know as well as I it has more to do with the planner covering his/her backside than actual rad safety. At least at the Lazy H it does

[Content1]

When I worked at site and lock rooms higher then just a High Radiation area, usually LHRA called for continuous coverage.  The joke was you were expected to do continuous coverage with more than one work group and on different levels.  You had to have very good eyes.   Many solve this with camera's and remote dosimetry monitoring of dose.

[Brett LaVigne]

There is no straight answer to the question. It depends on the site. Where I work, lots of things that would seem pretty routine and probably classify as intermittent coverage will be continuous due to the heavy fission products that make up most of our contamination. Constant coverage will depend on what you are working with and your managements expectations.

[Rennhack]

To add any insight I can, Ray is coming to us from Hanford. (daoutside.hanford.gov)

Some insight into the requirements at a DOE site are found in DOE-HDBK-1122-99 (The RCT Study Guide), In Section 2, Module eleven, Objectives 1-4.

http://www.nukeworker.com/study/hp/rct/index.shtml

http://www.nukeworker.com/study/hp/rct/pdf/2_11_Radiological_Work_Coverage_sg.pdf

[Rennhack]

To add any insight I can, Ray is coming to us from Hanford. (daoutside.hanford.gov)
Some insight into the requirements at a DOE site are found in DOE-HDBK-1122-99 (The RCT Study Guide), In Section 2, Module eleven, Objectives 1-4.
http://www.nukeworker.com/study/hp/rct/index.shtml
http://www.nukeworker.com/study/hp/rct/pdf/2_11_Radiological_Work_Coverage_sg.pdf

To add to my post, attached is the Hanford specific version of 2.11, where Ray is.  

In part, it mentions:

Job (or work) coverage can either be continuous or intermittent.

Continuous: sufficient to IMMEDIATELY influence or stop work based on observed radiological conditions and/or work practices; all conditions are continuously monitored for the duration of work.

Intermittent: coverage at frequent enough intervals to exclude any reasonable potential for unmonitored change.


Some radiological conditions or types of jobs that could require radiological control job coverage are:

$   Workers doses near limits

$   Radiation dose rates in the job area are high enough to potentially cause workers' doses to exceed administrative control levels in a short time.

$   Radiation levels are expected to increase significantly during the job.

$   Entry into high radiation areas.

$   The potential for spreading high levels of contamination or causing airborne radioactivity.

$   The potential for significant increase in contamination or airborne radioactivity levels during the job.

$   Inadequate personnel dosimetry for the type or levels of expected radiation (e.g., neutrons or low-range dosimeters).

$   Jobs performed by inexperienced workers.




It uses the following documents as references:

1.   HNF-5173; Project Hanford Radiological Control Manual
2.   HNF-5183; Tank Farms Radiological Control Manual
3.   HNF-13536 (FH); PHMC Radiological Control Procedures
4.   RPP-5779 (CH2MHILL); Radiological Control Instructions
5.   HNF-13536, 6.1.1 (FH); GM Portable Survey Instrument
6.   RPP-5779, RCI-80 (CH2MHILL); GM Portable Survey Instrument
7.   HNF-13536, 5.1.2 (FH); Documentation of Radiological Surveys
8.   USQ #02-0969, TFC-ESHQ-RP_ADM-P-09 (CH2MHILL); Documentation of Radiological Surveys
9.   10 CFR 34; Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial Radiographic Operations
10.   HNF-13536, 5.1.1 (FH); Required Radiological Surveillances

I would specifically check these procedure:  HNF-5173/HNF-5183.

Please understand that I've never worked at Hanfdord like Ray does, but I found this information with 2 min of searching.

[thenukeman]

Got an Emergency call on my Radio, I got to the the place I was called, They was loading a man on a ambulance that had serious third degree burns,  my buddy who got there a few minutes before I did said that guy ain't going to make it.  They airlifted the man to Erlanger burn center in Chattanooga TN,  He did not make it.  The RWP called for continous coverage. There was also no fire watch and the clothes he wore were fire starters instead flame retardent since they were washed so many times. since he did not live he did not get to tell his side of the story, the story goes that he took it upon himself to go back into the area to fetch something.  Then he burned up.  We will never know, but it was a lot of falures in this situation.  I swore from then on I would NEVER leave a job that called for continous coverage and never take safety for granted!!!

[HousePuke]

It does depend on the site, the Tech Specs, License Basis Documents and such.  Also for NRC licensed activities take a look at Reg Guide 8.38.  It is based on work in High and Very High radiation Areas.