Re: Gamma Radiography

[James G. Barnes <mail15077@pop.net>]

Good afternoon.

We use contract radiographers with some regularity.  Here is our approach:

    > Do you ask them if you may see their license and then get back and tell
    > them to notify you when their through?

We get involved well ahead of time.  We direct our purchasers and other 
contract representatives to obtain and submit a copy of the radiographer's 
license and a copy of his/her Rad Safety Manual two-three days prior to his 
arrival on site.  We then review the documents, and formally approve the vendor 
for work on our site.  If a vendor arrives without this approval, we don't 
permit them to shoot until we complete a document review.  Generally, this 
approach has worked very well as the vendor arrives forewarned of our site 
specific requirements, and we have a chance to estimate the competence of the 
vendor by reviewing his documentation.  You just have to make sure that you 
have gotten the word out to your purchasers and contracts types.
    >   
    > Do you get out your copy of 10 CFR 34 and/or state regulations and check
    > them out line by line?

We stipulate in the services contract that they work under their license inside 
and that they bear primary responsibility for the safety of the overall 
operation.  We also stipulate more esoteric issues, such as who provides 
dosimetry, etc.  We generally find that we have to be very demanding about 
barriers and access control; the vendors tend to be less vigilant than we feel 
comfortable with.  Other than that, we do not provide "regulatory" oversight of 
their operations.  We do periodically observe their operations from the 
standpoint of determining if the vendor may present a hazard to our site 
workers; and have contractual language to deal with any issues that arise from 
such oversight.

    > Do you participate in the zoning, do surveys and over see the whole
    > operation?

Generally, no.  We will, however, periodically check postings and barrier 
locations to ensure that they are living up to their obligations under the 
service contract and our stipulations.  I generally do not provide HP coverage 
for the vendor: that is his job and obligation.  Sometimes is very complicated 
geometries, we will participate in order to assist in the safe conduct of 
operations.

Note, however, that we may provide our own employees (non-HP) for access 
watches or other personnel support at the boundary if the radiographer needs 
the assistance.  We also instruct the contract coordinators that the 
radiographer is not to start operations if that radiographer does not feel 
comfortable with his ability to conduct operations in a safe manner; it's his 
license on the line so he should have that level of authority.


    > The deeper you get involved the more liability you assume in
    > the event of a boundary crossing and potential overexposure.

Yes, to some degree.  However, that liability may be far outweighed by the fact 
that you knew a potential hazard existed and made no attempt to observe and 
correct the situation.  We generally approach this from the viewpoint that we 
will assist the vendor in reducing the potential of our employees getting into 
harms way during a radiographic operation (evacuting facilities, etc.), but the 
vendor bears primary responsibility for the safe conduct of the operation.  
Generally, this is really an issue in scheduling and pre-planning.

    > If you from a nuclear power facility you have ample personnel to monitor
    > radiography but when your radiation safety staff is  2-3 people, what do
    > you do?  How involved do you get? 
    > 
Your assumption that NPS operations have "ample personnel" may not be true 
anymore.  I can recall many times during my commercial days where radiographic 
operations would give one fits.  More HPs generally made the situation worse 
because of the confusion and difficulty in communications.  Pre-planning and 
contractual language goes a long way to solve the problem; it may not be as 
personnel intensive if you can get prior notice of an upcoming shoot.

Hope this is of some use.

Jim Barnes, CHP
Radiation Safety Officer
Rocketdyne Division; Rockwell Aerospace


    > Phillip Llewellyn  
    > plllewellyn@tva.com
    > 
    >