Radiography at Nuclear Power Plants

[Phurst]

Is there an exemption for station posting requirements when posting for radiography or is the radiographer's postings sufficient? Radiographer's post only HRA and RA but Tech Spec conditions >1 R/hr could exist which would require barricading/guarding and do they post the RA at a number > area background or if they are already in a posted RA don't post at all? 10CFR34 sends the radiographer to 10CFR20.1902.

[Marlin]

Is there an exemption for station posting requirements when posting for radiography or is the radiographer's postings sufficient? Radiographer's post only HRA and RA but Tech Spec conditions >1 R/hr could exist which would require barricading/guarding and do they post the RA at a number > area background or if they are already in a posted RA don't post at all? 10CFR34 sends the radiographer to 10CFR20.1902.

   It's been a while for me but I remember both being used, there are two licenses involved and both must be adhered to. The radiographer is responsible for all of his operations but the site is still responsible for all exposure on site. I also remember adding "Radiography in Progress" inserts to our signs when we did the posting but the radiographer walked the boundaries to verify the posting. Remember that the regulation is millirem in one hour not mr/hr the radiographer probably has charts to comply with this so there may be conflict between the two.

[nickscott13]

Every radiography shot I have ever been a part of we posted LHRA.  Danger/LHRA/RIP/Keep Out
Then depending on the size of the effected area, we would post guards at the boundary to ensure noone came through.  We made the boundary size very conservative and our guards were always HPs so we could verify there were no HRA conditions on the outside of the LHRA boundary.

[SCMasterchef]

It is the responsibility of the Radiographer to post the affected area.  To post an area as a LHRA would require that the area be physically locked and or access controlled such that an unauthorized individual, meaning radiographer/radiography Assistant, could not enter the area by any means other than through a locked access or a control point posted individual.  Some plants do require that a boundary monitor perform walkdowns of the posted area, outside of the posted boundary, to insure that dose rates do not exceed the procedurally listed level.  The radiographer has the responsibility of insuring that the boundary that they have posted is sufficient to meet the requirements of the plant procedural requirements at all times.  I have seen Radiographer posted signage that indicated both RA up to HRA but never LHRA.  Radiographer posting will always indicated Keep Out and in about 99% of the time the inserts will indicate that "Radiography in Progress".

[Marlin]

Couple of comments

It is the responsibility of the Radiographer to post the affected area. 

It is his responsibility to ensure the area is posted.

To post an area as a LHRA would require that the area be physically locked and or access controlled such that an unauthorized individual, meaning radiographer/radiography Assistant, could not enter the area by any means other than through a locked access or a control point posted individual. 

   Locked High Radiation Area is license driven posting criteria based on plant specifications. Radiographers typically do not have those restrictions or requirements in their license except in permanent radiographic structures (built for radiography).

   Radiography can be a little confusing in a power plant and I agree with the bulk of your post.

[PWHoppe]

Many times the requirement for a LHRA is in the plants T.S. typically I have seen that number set at 1000 mr/hr. The requirement to have  the area "locked" can be accomplished by posting guards IAW station procedures.

[Fermi2]

Tech Spec Typically looks like this:

5.0 ADMINISTRATIVE CONTROLS
K. 5.7 High Radiation Area
5.7.1 Pursuant tol10 CFR 20. paragraph 20.1601(c), in lieu of the
requirements of 10 CFR 20.1601, each high radiation area, as.
defined in 10 CFR 20, in which the intensity of radiation is
> 100 mrem/hr but < 1000 mrem/hr, shall be barricaded and
conspicuously posted as a high radiation area and entrance thereto
shall be controlled by requiring issuance of a Radiation Work
Permit (RWP). Individuals qualified in radiation protection
procedures (e.g.. Radiation Protection personnel) or personnel
continuously escorted by such individuals may be exempt from the
RWP issuance requirement during the performance of their assigned
duties in high radiation areas with exposure rates 5 1000 mrem/hr,
provided they are otherwise following plant radiation protection
procedures for entry into such high radiation areas.
Any individual or group of individuals permitted to enter such
areas shall be provided with or accompanied by one or more of the
following:
a. A radiation monitoring device that continuously indicates
the radiation dose rate in the area.
b. A radiation monitoring device that continuously integrates
the radiation dose rate in the area and alarms when a preset
integrated dose is received. Entry into such areas with
this monitoring device may be made after the dose rate
levels in the area have been established and personnel have
been made knowledgeable of them.
c. An individual qualified in radiation protection procedures
with a radiation dose rate monitoring device, who is
responsible for providing positive control over the
activities within the area and shall perform periodic
radiation surveillance at the frequency specified by the
Radiation Protection Supervisor in the RWP.
(continued)
FERMI - UNIT 2 5.0-23 Amendment No. 134
High Radiation Area
5.7
5.7 High Radiation Area (continued)
5.7.2 In addition to the requirements of Specification 5.7.1. areas
accessible to individuals with radiation levels such that an
individual could receive in 1 hour a dose equivalent > 1000 mrems
but < 500 rads at one meter from sources of radioactivity shall be
provided with locked doors to prevent unauthorized entry, and the
keys shall be maintained under the administrative control of the
Nuclear Shift Supervisor on duty and/or the radiation protection
supervision. Doors shall remain locked except during periods of
access by personnel under an approved RWP that shall specify the
dose rate levels in the immediate work areas and the maximum
allowable stay times for individuals in those areas. In lieu of
the stay time specification of the RWP, direct or remote (such as
closed circuit TV cameras) continuous surveillance may be made by
personnel qualified in radiation protection procedures to provide
positive exposure control over the activities being performed
within the area.
5.7.3 For individual areas accessible to individuals with radiation
levels such that a major portion of the individual's body could
receive in 1 hour a dose > 1000 mrems with measurement made at
30 centimeters from the source of radioactivity, but < 500 rads at
one meter from sources of radioactivity that are located within
large areas such as reactor containment, where no enclosure exists
for purposes of locking, and where no enclosure can be reasonably
constructed around the individual area, that individual area shall
be roped off and conspicuously posted, and a flashing light shall
be activated as a warning device.
FERMI

[spentfuel]

Is there an exemption for station posting requirements when posting for radiography or is the radiographer's postings sufficient?
No and Yes
Radiographer's post only HRA and RA Correct unless the have a 1000 Ci Ir-192 source

but Tech Spec conditions >1 R/hr could exist which would require barricading/guarding this is not a posting but rather an access control measure

and do they post the RA at a number > area background or if they are already in a posted RA don't post at all? 10CFR34 sends the radiographer to 10CFR20.1902.seems to me you answered your own question they post as required per 10CFR20 or equivalent

Seems to me to be some confusion between posting and access control associated with locked high rad areas.  Some site specific procedures may require different postings for a LHRA but there is no regulatory requirement unless you have very high rad area dose rates.

Thanks BZ for the flashing light addition as thats mostly what I have seen but I have also seen blue flashing lights at radiography boundary's and yellow flashing lights at high rad areas in containment > 1 r/hr at a foot such as steam generator platforms with open manways.

Also I think this is a typo

high radiation areas with exposure rates 5 1000 mrem/hr,

unless Fermi dose not issue RWP's at 51 r/hr  

Ill also add most radiography I have dealt with is performed under an agreement state license

sf

[Marlin]

Seems to me to be some confusion between posting and access control associated with locked high rad areas.  Some site specific procedures may require different postings for a LHRA but there is no regulatory requirement unless you have very high rad area dose rates.

   LHRA is an access control but it is also a posting. This is generated by exceptions to the CFR in the License as has been stated it is commonly 1000 mr/hr but I have seen 3000 mr/hr. I don't think I have encountered a plant that did not post the LHRA areas (again my experience is a bit dated).

   Radiographers posting can be driven by license as well and there are many radiographic sources I personally have worked with radiographers using Ir191, Co60, X-Ray generators, and a linear accelerator.

[Phurst]

Thanks. That is a bunch of good info. I'm re-writing our radiography procedure and saw some conflicts so I thought I would ask. I am concerned about the access controls for radiograpahy. 10CFR34 doesn't discuss it and only requires posting IAW 10CFR20 but the station LHRA requirements meet the reg guide 8.38  for access control. We have our radiographers apply a radiation area boundary at the point the shot will increase dose rates 2 mrem/hr above the current dose rate so we end up with a RA inside a RA when they are shooting in places like RHR. We do guard access points and verify boundaries but I am not sure we fully meet the LHRA posting/access controls.

[Chimera]

Don't forget the need to walk down the area to ensure all personnel are out before the shot.  Once upon a time, we found a fire watch still in the area after the welders left.

[RDTroja]

Don't forget the need to walk down the area to ensure all personnel are out before the shot.  Once upon a time, we found a fire watch still in the area after the welders left.

I walked up to the back of a radiography sign once... scared me to death. They were just in the process of posting and the area was large enough that we could not see each other as the walked around the perimeter and I walked through the middle. When I came up to the back of the sign I thought 'I hope this doesn't say Contaminated Area' until I turned the sign over and suddenly wished it was a Contaminated Area.