RE: RWP requirements for radiography

[Stanley Fitch <stanley_fitch@nmenv.state.nm.us>]

Ms. Nissen:

Some perspectives on radiography in RCAs.

The answer is yes, you need an RWP if radiography is not addressed in
any of the SOPs for the RCA.  Primarily to address how the RCA's
radiological concerns will affect the radiographers.  Not on how the
radiographers will affect the RCA.  However, radiography will affect the
RCA, and this should be included in planning the radiographic operation.

Since U.S.A. radiographers are licensed by the NRC or Agreement States,
they are responsible for controlling the radiological hazards created by
their radiographic operations.  Because of jurisdictional authority, the
RWP should not set radiological controls for the radiographic
operation.  You would need, however, to work with the radiographers on
how their radiation combined with the RCA radiation will affect all
operations in the area.

Some years ago when I was at Sandia Labs, we had a conflict between
radiographic operations and an adjacent particle research Van de Graff. 
The Van de Graff had 2 mR/hr interlocks set at the building perimeter. 
However, the radiographer's 2 mR (for any one hour) exclusion area
overlapped the Van de Graff 2 mR/hr interlocks.  Naturally, the
radiographic radiation tripped the Van de Graff interlocks.  This became
a DOE reportable occurrence because the radiography tripped the
interlocks.  The moral of this story:  Plan ahead so radiography does
not influence your routine operations.

Respectfully,
Stan Fitch
stanley_fitch@nmenv.state.nm.us
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