Authorization and inspection of industrial radiography ...

AUTHORIZATION AND INSPECTION OF INDUSTRIAL RADIOGRAPHY PRACTICE

By

Adamu Midala HussainiDepartment of Authorization and Enforcement

Objectives

• To provide understanding of the authorization process and the procedures for Industrial Radiography

• To understand the role of the inspection and the procedures for its implementation in industrial radiography

Introduction• The NNRA was established by the Nuclear Safety and

the Radiation Protection Act 19 of 1995 (the Act).

• The Act charged the NNRA with the responsibility for nuclear safety and radiological protection regulation in Nigeria

• That NNRA shall ensure protection of life, health, property and the environment from the harmful effects of ionizing radiation while allowing beneficial practices involving exposure of ionizing radiation.

Introduction cont..

• Oil and gas industry is the largest user ofradioactive materials in Nigeria;

• They Make use of radiation generators and sealedand unsealed radioactive sources;

• Some of these are potentially dangerous to humanhealth and environment if not properly controlled;

Introduction• The use of ionizing radiation brings many benefits to

mankind and one of the longest established industrial applications is the use of radiography for non destructive testing (NDT).

• Industrial radiography provides a means of checking the physical integrity of equipments and structures such as vessels, pipes, welded joints, casting and other devices.

• The structural integrity of such equipment and structure affects not only the safety and quality of products, but also the safety of the workers and the public and the environment.

Use of ionizing radiation in Nigeria

As of present radioactive sources find uses in different

sectors of the Nigerian economy and these include the:•

• petroleum industry, • mining industry, • manufacturing industry, • construction industry, • agriculture and water resources, • the health sector, • education and research and• customs and security screening

Industrial Radiography

• Industrial radiography is:-• a process of non-destructive testing for

examining the quality of a component or product;

• most often utilized for quality control of metal fabrication for the oil/gas industry;

• also used to test a range of other products.

Types of Industrial Radiography Equipment

Common• gamma source projectors • directional x-ray• panoramic x-ray• x-ray crawlers• gamma crawlers• crawler control sources

Uncommon• betatron• linear accelerator• neutron radiography• torch devices• fluoroscopy

Industrial Radiography

Radiography is carried out during:

- the construction and maintenance of rigs andplatforms;

- laying of pipelines and prior to the hook up when the production and export systems are to be connected;

- examination of seabed pipelines, sub-sea assemblies and platform or rigs below the waterline.

INDUSTRIAL RADIOGRAPHY

Application in Industrial RadiographyFixed assemblies:• using X-ray generators or gamma emitting sealed

sources inside shielded facilities with engineeringcontrols;

Mobile assemblies:• using X-ray generators or gamma emitting sealed

sources outside shielded facilities such as for siteradiography

IONIZATION AND EXPOSURE PATHWAYS

Ionization• is the mechanism by which the

radiations used in IR can causeharm

• There are two main pathways forthe exposure of persons toradiation namely;

external exposure and

internal exposure


• External Exposure

• This is the predominant exposure route in IR

• A person handling or standing close to a sealedsource or an x-ray set may be exposed to theradiation being emitted

• The magnitude of the dose received will bedependant on:

Ø radionuclide and its activity, or,

Ø operating parameters of x-ray equipment;

Ø the degree of shielding; distance and time.


• Internal Exposure• This pathway of exposure arises as a result of

inhalation of radioactive material

• Perhaps as a result of suspension of a fractionof the source in the air as an aerosol or dust

• Or by the spread of surface contamination ofunsealed radioactive material

• Risk from internal exposure is very likely in IR.

CLASSIFICATION OF AREAS, LOCAL RULES AND SUPERVISION

• A primary mechanism for the restriction ofradiation doses is the control of access toareas where there is potential forsignificant exposure.

• Details are in NiBIRR Part IV – Designated Areas(Regulations 32 to 44)

• CLASSIFICATION OF AREAS IN IR• IAEA BSS defines two areas:• Controlled and Supervised areas

Controlled Areas in IR

• A controlled area is an area in which specific protective measures are required for controlling normal exposures and for preventing or limiting the extent of potential exposure• Boundaries are determined, delineated and marked with warning symbols;

• Occupational safety measures are established;• Access is restricted by administrative and physical

barriers

Controlled Areas in IR• 1. Radiography in shielded enclosure - The inside of radiography

compounds should be classified as controlled areas• 2. Site Radiography- A controlled area must always be designated

during site radiography.• The boundary dose-rate when collimators are used are typically in

the range of 7.5 µSv/h to 20 µSv/h. When it is not possible to use acollimator the boundary is in the range of 50 µSv/h

• Boundary distances for Ir-192 – 185 GBq (5 Ci) – 57 m; 370 GBq (10 Ci) - 80 m;740 GBq (20 Ci) – 113 m

• Boundary distance for x-ray source - 150 kV, 4mA – 730m; 300 kV, 4mA –894m

• 3. Sources StoresAreas set aside for storage of gamma sources used in IR must beclassified as controlled areas

• 4. EmergenciesTemporary controlled areas may required to be declared in theevent of accidents or incidents, e.g. as a result of a transportaccident or during source recovery

Controlled Areas in IR• Requirements for Controlled areas in IR

1. Demarcation (Delineation)• Must be physically delineated with signs and notices at all access points clearly

stating that the area is controlled• For a shielded enclosure, the walls, doors and roof will form the boundary of the

controlled area.• For site radiography temporary barriers (tape, chain) may have to be erected in

order to form a boundary of the controlled area.2. Restriction of Access

• Access to controlled areas should be restricted to authorized persons. This mustbe done by means of administrative procedures3. Monitoring

• Dose-rate monitoring must be carried out in and around all controlled areas• Results of such monitoring must be recorded and retained for information

4. Local rules• Work in controlled areas must be carried out in accordance with a written set of

local rules which describe the organizational structure and the procedures to befollowed in the controlled area.

Supervised Areas in IR

•A supervised area is an area where occupational exposure conditions need to be kept under review•Boundaries are determined and delineated.•Specific protection measures are not normally needed.Supervised areas are not common in IR

Local Rules and Supervision

The Local Rules shall describe:-• investigation or authorized levels and protective

measures;

• the information available to workers on risks and emergency procedures;

• the training program for personnel;

• the information, notification and arrangements to protect the foetus/embryo of pregnant workers;

• the health surveillance program for workers.


• LOCAL RULES IN IR• Are effective set of instructions that specify the manner in which IR

work should be carried out• So as to ensure adequate levels of protection and safety for workers

and the public and the environment.• Must reflect the practical requirements of NiBIRR 2003• It is the responsibility of the Licensee/radiation employer to provide

the local rules• Must be set down in writing

• Details in Regulations 34 and 35 of NiBIRR


• Local rules in IR must include the following as a minimum:• 1. Identification of person(s) responsible for supervising the

work. Must include RSO

• 2. Description of all controlled and supervised areas

• 3. General radiation safety procedures. Instructions as to howwork should be carried out in order to keep exposures to aminimum.

• 4. The value of dose investigation level set by the employer andthe procedures to be followed in the event of that level beingexceeded

• 5. Emergency plans detailing actions to be taken in the event ofany reasonably foreseeable incident or accident


• SUPERVISION IN IR• Employers are required to ensure that work involving occupational

exposure is adequately supervised and that all reasonable steps aretaken to ensure that local rules, along with any other safetyprocedures are followed

• In order to achieve this the RSO is expected to:1. Liaise with radiographers and management2. Supervise the radiation protection aspects of the work3. Be able to recognize the need to seek further advice when

appropriate.4. The RSO is the first point of contact within a company for matters of

radiation safety


• As a general rule an RSO in IR would be expected to:

• 1. Be someone in line management position but beinvolved in the work on a day to day basis (e.g. shiftsupervisor, foreman, etc)

• 2. Be familiar with the work in question• 3. Have received sufficient training in radiation protection

and safety in order to allow him to undertake the role

• The key role of the RSO is one of supervisionand employers must ensure that sufficientRSOs are appointed to achieve this

INDIVIDUAL MONITORING IN IR

• Individual monitoring is the measurement of radiation dosesto persons in order to ensure that doses are kept as low asreasonable achievable and are below dose limits.

• It comprises two components, dose assessment and health surveillance

• Such information is important for a number of reasons:• It enables control to be exercise over radiation exposure of an individual• It demonstrates whether or not doses are kept as low as reasonably achievable

(ALARA)• Unexpected or abnormally high doses can be highlighted• Dose data for a group of individuals can give an indication of working practices

and will reflect improvement or deterioration in these practices

• Details in Regulations 45 – 60 of NiBIRR


• DOSE ASSESSMENT IN IR• Means assessment of the radiation dose

received by individual

• Practically achieved by wearing of a dosimeter

• Industrial radiographers must be subjected to formaldose assessment

• The responsibility lies with the employer/licensee

• The employer/Licensee must make arrangementswith an authorized dosimetry service provider for doseassessment and associated record keeping


• HEALTH SURVEILLENCE is carried out to:• Assess the worker’s level of fitness for the

intended task• Assess the worker’s psychological suitability for

work with radiation source• Ensure the worker’s health remains satisfactory

• Records of health surveillance are confidential• Details in Regulation 55 and Seventh

Schedule of NiBIRR

Work place monitoring• The IAEA BSS and NiBIRR requires that IR registrants, Licensees

and employers establish and maintain workplace monitoringprograms.

• Such monitoring must provide sufficient information to allow:Ø Evaluation of the radiation conditions in all areas;Ø Assessment of potential exposures in controlled and supervised

areas;Ø Ongoing review of classification of controlled and supervised areas

• Monitoring is usually carried out under the supervision of the RSO ina manner advised by Qualified Expert

• Details in Regulations 42, 43 and 44 of NiBIRR

Authorization

Authorization means a permission granted in a document by the Authority to a legal person who has submitted an application to manufacture, supply, receive, store, use, transfer, import, export, transport, maintain or dispose of radioactive sources.

The authorization can take the form of registration or licensing.

Authorization• The operating organization will need to apply

for an authorization to acquire, store, and use of radiography sources.

• When applying for authorization, the operator should provide appropriate documentary evidence to demonstrate that an adequate level of radiation safety will be provided and maintained.

Legal Basis for Authorization

• Section 19 of the Act: …no source orpractice involving exposure of man toionizing radiation shall be authorized,except through a system of applicationnotification, registration or licensingestablished by the Authority;

Types of authorization

• Exemption• Registration (Premises)• Permit (Transportation)• Certificate• Licence (Use, Import, Export, Transfer)

Authorization Procedure§ Notification: (new practice, renewal for existing

practice or amendment to existing authorization)§ Application (Fill Application Form; Provide

Support Documents and Information; PayAppropriate Fees)§ Assessment of Application§ Inspection§ Inspection Report§ Review of Inspection Report§ Authorization granted- Licence, Certificate, Permit,

Exemption

§ Authorization Denied

Notification

Notification

• is the basic mechanism which provides information to the Regulatory Authority about a proposed action.

• An application for authorization may also serve as notification.

• Apparatus exempted by the Regulatory Authority may require notification (conditional exemption).

Notification

• provides useful information:-

• to identify the users and sources prior to initiating an authorization process;

• prior to making a decision about granting an exemption for certain types of sources;

• from the importers and dealers about the sources imported, exported and distributed.

Application

• Application shall include:

– Detailed information of the use of source– Radiation protection provisions– Provisions for source safety and security– Assessment of exposures– Arrangements for handling waste

Inspection

An examination, observation,measurement or test undertaken by theRegulatory Authority to assess structures,systems, components and materials, aswell as operational activities, processes,procedures and personnel competence

Legal Basis for Inspection

• Section 15(2) of the Act….. Shall inspect the premises to which the application relates and carry out such other investigations as will assist the Authority in arriving at a decision in the matter;

• Section 37(2)(a-d) also gives the Inspector the authority to carryout inspection without any form of hindrances from the operator

Types of Inspection

• Preauthorization Inspection• Preshipment Inspection• Compliance Inspection• Investigative Inspection• Audit Inspection• Decommissioning Inspection

Objectives of Inspection

• To ensure that the operator comply with the conditions set out in legislation, regulations and the conditions set for authorization.

• To ensure that facilities, equipment and work performance meet relevant regulatory requirements and standards;

• To ensure that deficiencies and deviations are identified and corrected without undue delay.

• Any lessons learned are identified and propagated to relevant stakeholders.

Objectives of Inspection

• Persons employed by the operator, including contractors, possess the necessary competence.

• Relevant document and instructions are valid and being complied with.

• that they do so in a manner that does not place any person at risk of unnecessary radiation exposure.

Inspection program

FrequencyPriority Announced or unannounced

Inspection program

Inspection prioritized according to the category of potential risk

Category 1: Industrial Radiography

Frequency of inspectionFrequency related to category of practice (safety risk):

Category A:• high risk: • every 1-3 years (e.g. site installation)

Category B:• medium risk: • every 3-5 years (e.g. fixed Installation)

Unannounced Inspection

Advantage: • provides the opportunity to see the facility

operating under its usual conditions.

Disadvantages:• key personnel may not be available, or

part of the facility may not be operating.

Inspection procedures and checklists

• Inspection procedures and checklists are for use by Regulatory Authority inspectors.

• They should identify the items to be checked according to the type of practice and may include advice to the inspector on acceptable and unacceptable performance criteria.

Inspection procedures

Pre-inspection preparation

Report and follow-up actions


Checklists

Conduct of Inspection


Pre-inspection preparation


Review previous correspondence, reports and violations.

Review particulars of the authorization (sources, locations,

etc)

Review any special conditions, restrictions or limitations

imposed on licence.

Select appropriate survey instruments


Conduct of Inspection

Interview key staff members

Observe procedures

Exit briefing

Entrance briefingGeneral tour of

facility

Allocate sufficient time to complete the

inspection in the required detail




Report and follow-up actions

Follow-up; enforcement;

data and record keeping

Report preparation; submission to

supervisor for review

Responsibilities and Behaviour of Inspectors

Professionalism• Inspectors shall be -• expert within their sphere of responsibility but recognising the

limitations of their personal technical knowledge;

• objective;

• receptive to information and opinions from others;

• inquisitive but not obtrusive.

Decisions should have transparency and clarity.


• Independence.

• Inspectors shall have no engagement in, or financial dependency with promotional or regulated activities;

• be formal and friendly (but not familiar) in transactions relating to regulated activities


• Helpfulness

• Inspectors shall:-• maintain a balance between information dissemination

and acting as a consultant;

• avoid providing detailed advice that might shift responsibility for operational safety to the regulatory staff;

• Balance depends on national circumstances; especially on the availability of suitably qualified and experienced persons outside the regulatory framework.


• On site enforcement

• Inspectors shall:-• respect their authority and not abuse their position;• inform their supervisor of actions taken (as defined by

internal guidance procedures on the allocation of duties and responsibilities);

• limit enforcement to that necessary, based on the perceived threat to health and safety;

• ensure that their actions are justified, proportionate and transparent;

Recommendations

More seminars on similar topics to serveas refresher course

Audit Inspection of some selected IRcompanies

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