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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 20 of 56
Roles and responsibilities of emergency response personnel (i.e. who will put the plan
into effect).
Details of the equipment to be used (i.e. the „emergency kit‟).
The ERP may be a stand-alone document, or it may be part of the radiation procedures.
5.2.3.9 Classified / Category A Personnel
Where work requires Classified / Category A Personnel (persons likely to receive an effective
dose in excess of 6 mSv per year, or an equivalent dose that exceeds three-tenths of any
relevant dose limit
- see definitions Appendix A), the contractor must provide suitable
people. The contractor will provide a suitable radiation dose monitoring system for such
people and ensure adequate medical surveillance.
The above will be applied retrospectively in the case of contractors already carrying out work
with ionising radiation on AzSPU managed sites.
5.2.4 Completion of Contractor’s Checklist by AzSPU Site RPS
Prior to any work with ionising radiation being carried out for the fist time on an AzSPU
managed site, the Site RPS will carry out an audit of the contractor, using the Contractors
Checklist (Appendix M).
The aims of the Checklist are to enable the Site RPS to verify that the Contractor‟s personnel:
have the necessary Special Permit for the work;
have the necessary details regarding radioactive materials;
have the necessary equipment for restricting exposures;
have suitable and sufficient radiation monitoring instruments for monitoring radiation
levels in the workplace and in the event of an accident, and that the instruments have been
tested;
have copies of the radiation procedures/local rules;
have sufficient RPOs to cover the scope of work;
have suitable personal dose meters;
have copies of their Emergency Response Plan and that any kit identified in the ERP is
available and in good order;
have suitable arrangements for accounting for any radioactive materials.
The information that the contractor is required to have could include decay charts, wipe-test
certificates, authorisations, registrations and calibration certificates.
In the event that a Contractor does not meet the criteria set down in the Contractors Checklist
then the Site RPS will notify the Site Manager / OIM. The OIM will decide whether or not to
allow the work to go ahead and record his decision on the Contractor‟s Checklist.
A permit will not be issued for work with ionising radiation unless the Contractor‟s Checklist
has been completed and been signed by the Site RPS and the Contractor‟ representative and if
necessary the Site Manager / OIM.
5.2.5 General Arrangements for Managing Contractor Sources on Site
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 21 of 56
5.2.5.1 Storage of Radioactive Substances
The basic principles to be applied in the case of storing radioactive substances are to ensure
that there is adequate security and that the materials are stored such that persons in the
vicinity are not exposed to significant levels of radiation. The materials should also be stored
such that there is unlikely to be any damage to the containment system that could lead to a
release of radioactive substances into the work area.
All contractor radioactive substances must therefore be stored to prevent unauthorised access
to those substances. Any small easily transportable container or package that contains
radioactive substances must be kept locked and in a dedicated storage area that is accessible
only to the contractor, the AzSPU Site RPS and the Site Manager / OIM.
The storage area must provide protection from the effects of the weather. In the case of
radioactive substances that are transported to site in secure overpacks, that can not be easily
transported by an individual or individuals, then it is acceptable to store the substances in
these overpacks provided rainwater could not accumulate in or on the container.
Source containers must be stored so that the dose rate at the boundary of the storage area does
not exceed 7.5µSv/h. Any area in which the whole body dose rate does exceed 7.5 µSv/h
must be designated as a Controlled Area and barriered.
Sources must not be stored with explosives or pyrophoric material. The Site RPS should use
his judgement as to the extent that each should be separated, taking into account the
protection afforded by the transport containers and the quantity of explosives present.
5.2.5.2 Source Records
Each time radioactive substances are brought onto an AzSPU managed site, the Site RPS
must record the details of the radioactive substances in the Site Mobile Source Movement
Register (Appendix N). The Source Movement Register must subsequently be updated when
a radioactive substance is either transported off the site or installed in plant equipment e.g.
nucleonic gauges.
Occasionally there is a requirement for small radioactive marker sources to be fixed down
hole (e.g. Cobalt-60 sources). Once these sources have been fixed down hole the Source
Movement Register should be updated with details of the particular well and the depth at
which the source was installed. Details of the source and its location should then be added to
the Site Inaccessible Source Register (Appendix O).
The same arrangements should be made for well logging sources that are stuck down hole and
are deemed irretrievable.
5.3
General Work Instructions for Working with Ionising Radiation
The following general instructions should be followed for all work with ionising radiation
carried out by Contractors. Instructions specific to the nature of the work are also given in
Section 5.4 Work Instructions for Site Radiography, Section 5.5 Work Instructions for Well
Logging, and Section 5.6 Work Instructions for Storage and Use of Pip Tags, and Section 5.7
Work Instructions for Nucleonic Devices.
The contractor will have procedures for the safe use of the sources available on Site. A
risk assessment must be available for the operation.
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 22 of 56
The contractor will appoint one or more of his employees on the Site as the RPO. The
contractor‟s RPO will co-ordinate with the AzSPU RPS in all aspects of the work
involving ionising radiation. He will provide his procedures and registrations to the
AzSPU RPS.
Work with ionising radiation comes within the Permit to Work System (ISSOW). An
appropriate permit must be raised prior to work starting.
The AzSPU Site RPS must complete the Contractors Checklist (Appendix M) to confirm
that all of the contractor arrangements are satisfactory before work commences.
Contractor sources must be recorded as mobile sources in the Mobile Source Register
(Appendix N).
Announcements of impending radiation work will be given over the Site public address
system as part of the PTW requirements, at
30 and 15 minutes before the work
commences. The announcement will give the location and duration of the work.
A Controlled Area will be designated for the duration of the work and will include areas
above and below the work site if necessary.
In general only the contractor‟s personnel will work within the Controlled Area.
There must be at least two individuals in the contractor‟s team and at least one of them
must be an RPO.
The dose rate at the boundary of the Controlled Area must not exceed
7.5 µSv/h.
Mobile barriers or bunting tape will be erected around the Controlled Area.
Warning signs will be erected around the Controlled Area indicating the radiation hazard
e.g. “Controlled Area. External Radiation Risk. No Entry”.
The Contractor must provide calibrated monitors appropriate to each type of radiation
used e.g. gamma and neutron.
An announcement will also be made when the work is completed.
All sources must be returned to the radioactive substance store when not in use.
NB: Instructions for contractors involving incidents with ionizing radiation are included
within the AzSPU Radiation Contingency Plan (AzSPU-HSSE-DOC-00086-2).
5.4
Work Instructions for Site Radiography
Radiography is used on AzSPU Sites to verify the integrity of welds, corrosion studies and
other NDT investigations.
The radioactive sources that are most commonly used in industrial radiography are listed
below with corresponding details of the maximum activity of source that should be used on
any AzSPU Managed Site.
Maximum source activities for general radiography use are:
Source
Maximum Activity
Iridium - 192
1000 GBq
Ytterbium - 169
5000 GBq
Selenium - 75
2000 GBq
Cobalt - 60
Each job must be discussed
with the RPA
In addition to the General Work Instructions for Working with Ionising Radiation (Section
5.3), the following specific instructions are applicable:
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 23 of 56
In the case of industrial radiography carried out onshore, all work with transportable
items will be carried out in a dedicated radiography enclosure, unless the risks associated
with the transport of the item to be inspected or resulting from the delay in transporting
the item, outweigh the risks of carrying out site radiography.
Where a contractor proposes to use either a cobalt-60 source (which is a high energy
gamma source), or a source with an activity higher than listed in the table above for that
type of source, the RPA must be consulted prior to the work commencing.
The RPA must also be consulted where the contractor proposes to use a source type that
is not listed, including X-ray equipment.
If the work piece to be tested is portable, it should be taken to a dedicated area for
radiography.
The area used for radiography on Site must be described in Site-Specific Instructions for
that Site. If the work piece is not portable, radiography must take place with the area
down-manned as far as possible.
If possible, the work should be carried out when other people are not around, for example,
at night or at meal breaks.
Flashing amber warning lights will be erected at all entrances to the Controlled Area.
A flashing red warning light will be situated adjacent to the source exposure position
while an exposure is underway.
Warning signs will be erected around the Controlled Area indicating the radiation hazard
e.g.
“Controlled Area. External Radiation Risk. No Entry” and will include an
explanation of the meaning of the warning lights e.g. “Amber Light: Radiation Imminent”
and “Red Light: Radiation Exposure Underway”
The Controlled Area must be thoroughly searched prior to any exposure.
A horn or whistle must be sounded just before exposure. The significance of this warning
must be indicated to the work force.
The Contractor must provide two suitably calibrated radiation dose rate monitors.
The Contractor must ensure that the source is back in its container at the end of the
operation by checking with a suitable meter.
An announcement will also be made when the work is completed.
All sources must be returned to the radioactive substance store when not in use.
NB: Specific instructions for contractors involving incidents with radiography sources
are included within the AzSPU Radiation Contingency Plan (AzSPU-HSSE-DOC-00086-
2).
5.5
Work Instructions for Well Logging
Well logging is used extensively on AzSPU Installations to obtain petrophysical, geological
and directional data.
The radioactive sources most commonly used in well logging tools are:
Source
Maximum Activity
Caesium-137
Up to 60 GBq
Americium-241/Beryllium
Up to 600 GBq
Additionally, some logging tools generate Pulsed Neutrons and incorporate around 60 GBq of
hydrogen-3 (also called Tritium).
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 24 of 56
In addition to the General Work Instructions for Working with Ionising Radiation (Section
5.3), the following specific instructions are applicable:
On occasion it may be necessary for workers who are not part of the logging crew to
work within the Controlled Area e.g. a driller working in the dog-house during
logging operations. In this instance the contractor will provide a written system of
work for such individuals and make an assessment of the individual‟s radiation
exposure. Details of the exposure will be passed to the Site RPS to record in a
Radiation Exposure Log (Appendix E).
Before any sources are run down hole, it must be ensured that there is free access for
the logging equipment to prevent it from becoming trapped.
The contractor must ensure that the logging tool is free from sand, clay or other dirt
before the source(s) is installed in the tool.
Remote controlled devices (e.g. handling tools) must be used when removing sources
from shields and inserting into the down-hole tool.
The Contractor must ensure that the source or sources have been loaded into the
down-hole tool prior to leaving the drill floor by carrying out radiation monitoring in
the area.
When the source or sources are returned the logging engineer will carry out another
radiation survey to ensure that the sources have been correctly loaded into the
storage/transport containers.
The above precautions also hold if a logging while drilling source is loaded and
removed from the tool. On these occasions, the Controlled Area may go down
through several decks as the sources are run into the well.
NB: Specific instructions for contractors involving well logging radioactive source
incidents are included within the AzSPU Radiation Contingency Plan (AzSPU-HSSE-
DOC-00086-2).
5.6
Work Instructions for the Storage and Use of Pip Tags
Pip tags, or depth correlation subs, are small sources that are inserted into the casing or tubing
string at a known point. The string is then installed in the well. The pip tag then acts as a
reference point for subsequent well logging.
Pip tags are usually Cobalt-60 sources. There are requirements over the control, storage,
disposal and notification of loss of the sources. Whenever possible the source should be
loaded into the collar or pup joint before transportation to the Site or rig.
In addition to the General Work Instructions for Working with Ionising Radiation (Section
5.3), the following specific instructions are applicable:
On receipt of the pip tag sources offshore they must immediately be taken to the source store
and placed inside. The well logging contractor must have his own source store. If the pip tag
is already installed in a collar or sub, it cannot be stored in the source store. The dose rate at
the surface of the collar or sub will be measured. An assessment of the external radiation risk
associated with the use and handling of the collar or sub must be carried out. If this risk
assessment indicates potential exposure to any member of the workforce in excess of 1mSv
per year, a supervised area must be established. If the dose rate exceeds 7.5μSv/h, a
controlled area with a barrier must be set up at the 7.5μSv/h contour. Signs giving warning of
the controlled or supervised area must be displayed in suitable positions indicating the nature
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 25 of 56
of the radiation sources and the risks arising from such sources. Details of the sources will be
entered on the form in Appendix N Mobile Source Register.
If the source has to be loaded into the collar or pup joint on the Site/rig, it must not be touched
by the fingers but handled using tweezers or tongs.
It is unlikely that a controlled area will be merited for pip tag work, but it is good practice to
provide a supervised area when handling pip tags and to barrier and mark that area.
The area must be prepared before use to aid source recovery if dropped. Whenever possible, a
tray (with a soft cover on) should be placed beneath the source loading area during the
operation.
All sources must be returned to the store when not in use and the keys returned to the OIM.
Where milling operations are likely to mutilate or destroy a pip tag located down a well, this
information must be immediately relayed to the AzSPU RP SPA and the RPA.
When the pip tag is installed in the well, the entry in the Mobile Source Register must be
closed out, with the well no. in which the pip tag has been installed. It must then be entered
in Appendix O Inaccessible Source Register. The position of any pip tags must be marked in
the well file. Although not required by legislation it is also good practice to have their
presence marked on the wellhead.
5.7
Work Instructions for Nucleonic Devices
Radioactive sources can be installed as part of nucleonic instrumentation for:
Monitoring and/or controlling density of fluid flowing through pipelines;
Monitoring and/or controlling liquid levels in vessels;
Detecting interface between fluids of different densities such as water, oil and gas in
vessels.
Nucleonic devices incorporate sealed sources of radioactive material that emit penetrating
gamma radiation. The varying absorption of the emitted radiation by the medium under
investigation and the subsequent detection of the attenuated radiation provides the basis of the
measurement techniques.
In the case of level or density gauges the sources are usually housed in heavily shielded,
secure steel and lead containers that are mounted onto vessels or pipes.
Some interface measuring / detecting devices are mounted with the source or a string of
sources located inside a vessel in a dip pipe, with an external housing into which the source(s)
can be withdrawn and shielded. The detector is also mounted external to the vessel.
For the above nucleonic devices, the type and activity of the source is determined by a
number of process parameters including vessel wall thickness and distance from source to
detector. Most nucleonic devices incorporate caesium-137 sources, but cobalt-60 is also used
in some situations due to the higher penetrating power of the gamma rays emitted.
Density profiling instruments (the „Profiler‟), used for density measurements through the
depth of a vessel, use an array of americium 241 sources, which may extend to a few metres
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 26 of 56
in length. The sources are contained within a source rod housed in a titanium dip pipe. The
device also incorporates an array of detectors in close proximity to the sources; there are no
detectors external to the vessel. Due to the low energy of the gamma radiation emitted from
americium-241, it is not normally possible to measure a dose rate on the outside of a vessel
fitted with a profiler.
5.7.1 Management Arrangements
Site Management have the ultimate responsibility for ensuring that installed nucleonic devices
are used in compliance with this procedure. This responsibility cannot be delegated to
employees, workers, the radiation protection supervisor (RPS), the RPA, the AzSPU RP SPA,
or anyone else.
All persons who may be affected by the content of these procedures should be made aware of
the relevant details. Site management will enable a free flow of radiation protection and
safety related matters between workers and management.
5.7.2 Critical Examination on Installation
Sections 5.2 and 5.3 must be applied in the case of Contractor‟s installing nucleonic devices.
In addition, the following requirements also apply:
A critical examination will be carried out when a nucleonic device is either installed for the
first time, or when any work is carried out on the device that could affect the safety aspects of
the device. It is the responsibility of the Contractor installing the device to carry out the
critical examination.
A site RPS will be present at the time of the Critical Examination to confirm the checks
carried out by the installer and he will complete the Critical Examination Checklist (Appendix
H). The RPS should ensure that the installer includes a check on the surface dose rate and the
dose rate at 1m and records the results in the Critical Examination Report.
Once the RPS is satisfied that a gauge has been installed satisfactorily, he will countersign the
Contractor‟s check-sheet to confirm that the checks have been carried out and that he agrees
with the results.
The site RPS will also sign the relevant documentation to formally accept the transfer of
ownership of the radioactive source(s) from the Contractor. The RPS will retain copies of the
source transfer document, the Contractor‟s Critical Examination Report and his own Critical
Examination Checklist. These will be retained in the Site Radiation Records.
5.7.3 Controlled and Supervised Areas
Controlled areas:
Controlled areas will be designated in accordance with the Radiation Protection Programme
requirements (see Section 5.1.1).
In most situations it should be possible for the Company installing the nucleonic devices to
ensure at the planning stage that the conditions requiring a designation of a Controlled Area
will not be created.
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 27 of 56
In the event that a Controlled Area is required, the site RPS will contact the AzSPU RP SPA
and RPA for further advice.
In addition, the dose rate at 1 m from a nucleonic device must not exceed 3 Sv/h and the
dose rate on the surface of the device must not exceed 100 Sv/h.
During vessel entry operations, it will be necessary to designate a Temporary Controlled Area
to allow access to the inside of the vessel, see Section 5.7.9.
Supervised Areas:
A Supervised Area will be designated around each installed nucleonic device to within 1
metre of the source housing and the detector.
Supervised Area signs are not required. Access to Supervised Areas will not normally need
to be restricted.
5.7.4 Site Register of Installed Sources
The Site Manager is responsible for ensuring that an up to date Site Register of Installed
Sources is kept; on a day-to-day basis this will be maintained by the RPS. The Register will
be updated each time a new source(s) is installed on site or whenever a source(s) is removed
from site, even temporarily. The Register forms part of the Site Radiation Records and is a
controlled and auditable record. The Register must contain the following information for
each source:
Type of source (e.g. caesium-137);
Source serial number (or other unique identification mark);
Date of receipt (i.e. the date that the source was installed and ownership transferred);
Activity of the source at the date of receipt or previously recorded date (manufacture);
Current location of each source;
For sources transferred from site, the date of transfer and the destination.
Additionally, a Site Map of Radioactive Source Locations, including source storage areas,
will be compiled and maintained by the RPS. This will be shared with the ERT.
5.7.5 Source Accounting
An RPS or an Authorised Person will account for each installed radioactive source on a
monthly basis. The purpose of the accounting check is to confirm that the source has not
been stolen or tampered with. A visual check on the actual source would incur unnecessary
exposure to the individual involved. Instead, the check will be carried out to confirm visually
that the source holder is in place and padlocked and that the source holder and/or padlock
have not been tampered with. For devices that are normally inaccessible, this check can be
confirmed using binoculars.
The source accounting checks will be recorded on the Radioactive Source Accountancy,
Monitoring and Safety Checks record form (Appendix I).
An inventory of radioactive sources for each site must be sent to MENR, MES and Ministry
of Health before 15 December each year. The Permitting and Regulatory Affairs Adviser will
be responsible for this, working with the AzSPU RP SPA.
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators
Page 28 of 56
5.7.6 Radiation Monitoring
The purpose of carrying out radiation monitoring is to demonstrate that radiation levels have
not changed significantly and that the area designation has not changed.
The monitoring should demonstrate that the dose rates that are accessible do not exceed 3
Sv/h at 1 m from the source housing and 100 Sv/h on the surface. In addition, the dose rate
at 30 cm from the source housing, detector or the surface of the vessel on which the nucleonic
device is installed should not exceed 7.5 Sv/h and 75 Sv/h for hand or forearm access.
Radiation monitoring will be carried out around each installed source or nucleonic gauging
device once a month, at the same time as the Source Accounting Check. Either the RPS or an
Authorised Person using a suitable dose rate meter that has been tested within the last 12
months will carry out the check.
The radiation monitoring results will be recorded on the Radioactive Source Accountancy,
Monitoring and Safety Checks Records Form (Appendix I) - the status of the shutter (i.e. open
or closed) at the time of the measurements will be recorded.
5.7.6.1 Nucleonic Level Alarms
The dose rate will be measured on the source housing, at 30 cm from the housing and the
detector and at 1 m from the source housing.
5.7.6.2 Interface Gauges
The source(s) is normally installed in a dip pipe inside the vessel, so the dose rate should be
measured at 30 cm from the surface of the vessel, or the next nearest accessible point. The
dose rate should also be measured at the detector.
5.7.6.3 Profiler Gauges
The sources are installed in a dip pipe inside the vessel. The americium-241 sources used in
the Profiler gauge emit low energy gamma rays, which do not have enough energy to
penetrate the vessel walls. It will not normally be possible to measure a dose rate outside the
vessel. A check should be carried out to ensure that there are no elevated dose rates around
the vessel or the device.
5.7.7 Maintenance and Safety Checks
5.7.7.1 Maintenance
Nucleonic gauges can be affected by the environment in which they are used, which may
result in the radiation safety and protection of the gauge being adversely affected, for
example, shielding may be degraded, shutters may stick, warning notices may become
illegible, etc. It is therefore important that gauges are included in a routine maintenance
schedule. Persons carrying out the maintenance work need to be aware of the radiation
hazards and be appropriately trained.
5.7.7.2 Safety Checks
The RPS or Authorised Person will carry out the following routine safety checks at the same
time as the source accountancy and radiation monitoring checks:
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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Inspect the general condition of the nucleonic device for wear, corrosion etc. and to
confirm that it is securely mounted.
Check that the padlock on the source holder is still in place and is in good condition.
Check that the source detail plate and warning sign on the nucleonic device and the
warning signs on the vessel are still in place and in good condition.
Check the condition of the shutter mechanism ensuring that the shutter has not been
padlocked in the “OPEN” position and that the status of the shutter is clearly visible.
At least once a year, the operation of gauge shutters should be tested and sources installed in
dip pipes should be isolated and de-isolated to ensure the continued safe operation of the
devices; this should be carried out by the RPS or an Authorised Person, with the permission
of the Control Room.
The results of these checks will be recorded on the Radioactive Source Accountancy,
Monitoring and Safety Checks Record Form (Appendix I).
5.7.8 Leakage Testing
When a new radioactive source is purchased it should be supplied with a certificate
confirming that it is free from contamination. Sealed sources used in nucleonic gauging
devices must thereafter be tested for leakage at least once in every 24 months, or annually in
the case of sources that are older than
15 years. Gauges that are used under harsh
environmental conditions (e.g. high temperature, corrosive chemicals, and high levels of
vibration) may need to be checked more frequently.
The purpose of the leakage test is to confirm that the source capsule is intact and that there is
no leakage of radioactive material. Given that a direct test of the source capsule would cause
a significant exposure to the person carrying out the test, an indirect method will be used
instead. This involves wiping the external surface of any part of the gauge where leakage
could reasonably be detected e.g. at the source holder / shutter mechanism.
The Site RPS or an Authorised Person who has received the appropriate training will carry
out the test. Alternatively, the test may be carried out by the RPA during the annual audit.
The procedure for carrying out a leak test is given in Appendix J. Wipes should be sent to the
AzSPU approved laboratory for analysis.
The certificate issued by the laboratory will require the signature of the person doing the wipe
test to confirm that the swab was taken in accordance with the procedure.
Where the wipe test is carried out by the RPA, the certificate will be signed by the RPA.
Copies of the leak test certificates will be maintained in the Site Radiation Records for a
period of at least two years.
5.7.9 Entry to Vessels Fitted with Nucleonic Devices
During routine operating conditions it is not normally possible to access the internals of a
vessel on which a nucleonic(s) is installed. However, during shutdown or maintenance
activities, vessel entry may be required.
Prior to vessel entry, a Site RPS will isolate any sources that are installed on the vessel. This
must only be carried out with the permission of the Area Authority. The isolation procedures
for sources installed in dip pipes and for the Profiler sources are given in Appendices J and K,
Control Tier:
2-AzSPU
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respectively. In the case of level and density gauges, the sources can be isolated by simply
closing the shutter on the source housing / container. The shutter should then be locked in the
“SHUT” or “CLOSED” position using a padlock. The padlock key will be kept by the RPS
until the source needs to be de-isolated.
The RPS is responsible for ensuring that the isolation procedure has been carried out and for
reinstatement and signing the work permit and/or isolation control certificate as appropriate.
5.7.9.1 Temporary Controlled Area
The inside of the vessel is normally designated as a Controlled Area due to the potential for
exposure to significant dose rates.
At the first opening of the man-way into the vessel, the RPS will confirm that the source(s)
have been isolated by monitoring inside the vessel with an intrinsically safe dose rate meter.
Provided there are no dose rates in excess of 7.5µSv/h, work can commence and the area can
be de-designated. It is not necessary to record the dose to the RPS in this instance. If the
dose rate is in excess of 7.5µSv/h, the RPS will withdraw and check that the source isolation
procedure has been carried out correctly. It should be noted that an exposed source, or
sources, would give rise to dose rates substantially in excess of 7.5µSv/h.
5.7.9.2 Naturally Occurring Radioactive Material (NORM)
If there is reason to suspect the presence of naturally occurring radioactive material in the
vessel then a check must be carried out before entry to the vessel is permitted. If NORM is
detected the AzSPU Procedure for Management of NORM (AzSPU-DOC-HSSE-00097-2)
must be followed and a task based risk assessment carried out. It should be noted that NORM
deposits could influence the dose rate measurement made above. A Controlled Area must be
designated for entry to a vessel containing NORM.
5.7.10 Precautions for Vessels Incorporating Nucleonic Interface Gauges
During normal operations, the source is retained in a dip pipe inside the vessel and the fluids
inside the vessel provide adequate shielding. If the liquid level inside the vessel falls, or is
lowered, it is possible that radiation dose rates outside the vessel will increase; the dose rate
that is likely to be present in the event of the loss of liquid level would be around 50 µSv/h.
In this event, the Control Room Operator will instruct an Authorised Person or RPS to retract
the source(s) into the shielded container and to lock the device in the “SHUT” position. The
RPS will retain the key and will ensure that the source is not exposed until the fluid level has
increased to the normal level.
For operational reasons it may occasionally be necessary to operate the gauge with the source
exposed above the liquid level. In these circumstances the RPS must measure the radiation
dose rate outside the vessel. If the dose rate exceeds 7.5 Sv/h then a Controlled Area should
be designated and signs and barriers should be put in place.
5.7.11 Removal of an Installed Nucleonic Device
Under no circumstances may a radioactive source be removed from its shielded
container.
Prior to removing an installed nucleonic device, the AzSPU RP SPA and the RPA must be
consulted and a task risk assessment must be carried out.
Control Tier:
2-AzSPU
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If it is necessary to remove the device from the vessel, either temporarily or permanently, the
RPO must ensure that the appropriate source isolation has been carried out and confirm this
by checking with a dose rate meter. The container may then be moved to an appropriate
storage location.
If the nucleonic device is refitted, the RPS will remove the padlock and open the shutter. The
RPS will then monitor the area and confirm that the readings are consistent with those made
during the critical examination. If they are not then the source(s) must be isolated, the area
monitored and the AzSPU RP SPA and the RPA contacted.
5.7.12 Temporary Storage of Nucleonic Devices
To ensure the safety and security of the sources, a temporary storage facility should:
provide adequate shielding;
be physically secure (e.g. locked when not in use);
not be used as a general storage area for other goods;
be fire proof and not contain other hazardous materials (e.g. flammable liquids and
explosive materials);
be dry;
be appropriately labelled (e.g. radiation trefoil and warning notices with the legend
“RADIOACTIVE” in English, Azerbaijani and Russian).
When nucleonic devices are placed into temporary storage, a daily accounting check should
be carried out by a RPS; and the Site Register of Installed Sources amended to reflect the
change of location.
5.7.13 Source Disposal
As soon as a nucleonic device becomes redundant, i.e. when there is no foreseeable use for
the device, arrangements should be made for its disposal and the AzSPU RP SPA and the
RPA should be informed. The means of disposal will normally be return of the device to the
supplier. The entire nucleonic device should be removed, in preference to just the source(s).
However, if this is not practicable for operational reasons and only the source(s) is removed,
then all warning signs should be removed from the device and a tag should be attached which
indicates that the radioactive source has been removed.
The supplier should be contacted to arrange for personnel to decommission the device. This
will require Sections 5.2 and 5.3 to be followed. Additionally, the AzSPU RP SPA and
Permitting and Regulatory Affairs should be notified of the planned disposal and the intended
change to the inventory of sources.
It must be ensured that the Contractor has the necessary Special Permit to carry out the work
and any other permissions and export licences required to dispose of the source(s). It should
also be ensured that the Contractor has made arrangements for onward shipping and where
necessary, temporary storage.
On completion of the work the Site Register of Installed Sources must be updated to reflect
the change in the source inventory and the source transfer documents should be added to the
Site Radiation Records.
At no time should a BP employee remove a radioactive source from a nucleonic device.
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
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6
Key Documents/Tools/References
This procedure shall, where appropriate, be used in conjunction with the following AzSPU
procedures:
Document Number
Title of Procedure
AzSPU-HSSE-DOC-00097-2
AzSPU Procedure for the Management of NORM
AzSPU-HSSE-DOC-00086-2
AzSPU Radiation Contingency Plan
AzSPU-HSSE-DOC-00115-2
AzSPU Procedure for Transportation of Radioactive
Materials.
AzSPU-HSSE-DOC-00083-2
AzSPU Procedure for The Import / Export of Radioactive
Materials and Sources of Ionising Radiation
AzSPU-HSSE-DOC-00025-2
AzSPU HSSE Document Management Procedure
AzSPU-HSSE-DOC-00021-2
AzSPU HSSE Definitions
AzSPU-HSSE-DOC-00002-2
AzSPU SSOW Procedure for Control of Work
AzSPU-HSSE-DOC-00011-2
AzSPU Procedure for Deviations
AzSPU-HSSE-DOC-00060-2
AzSPU Procedure for Permit to Work
AzSPU-HSSE-DOC-00054-2
AzSPU Incident Reporting and Investigation Procedure
AzSPU-HSSE-DOC-00072-2
AzSPU Review/Revision Process for HSE Tier 2 Procedures
- Terms of Reference (ToR)
AzSPU-HSSE-DOC-00063-2
AzSPU SSOW Procedure for Task Risk Assessment
Revision/Review Log
Revision Date
Authority
Custodian
Revision Details
20 October 2004
Alan McNulty
Abbas Islamov
Initial Issue
07 November 2008
Alan McNulty
Adalat Mammadov
Note: the next review/revision date is
extended to
01.03
2009 due to
rescheduling
05 December 2008
Yuliy Zaytsev
Adalat Mammadov
Authority position/name has changed to
reflect org changes in HSE&TD as of
December 1st 2008
24 June 2009
Yuliy Zaytsev
Adalat Mamedov
Next revision date extended to 15 July
(Safety &
(Central Safety TL)
2009 due to rescheduling
Compliance
Manager)
31 July 2009
Yuliy Zaytsev
Niyaz Mamedov
Document substantially reworked with
(Safety &
(HSE
input from AzSPU‟s Radiation
Compliance
Systems/CoW
Protection Advisor and expanded to
Manager)
Advisor)
include the following:
AzSPU Ionising Radiation Policy.
Radiation Protection Programme.
Management of contractors working
with ionising radiation.
Work instructions for site
radiography, well logging, pip tags
and nucleonic devices.
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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7th October, 2009
Yuliy Zaytsev
Idrak Nazarov
Information regarding naturally
(Safety &
(HSE MS Team
occurring radioactive materials (NORM)
Compliance
Leader)
has been removed from this procedure
Manager)
and incorporated into a separate AzSPU
Procedure for Management of NORM
(AzSPU-HSSE-DOC-00097-2).
Information regarding transportation of
radioactive sources has been removed
from this procedure and incorporated
into a separate AzSPU Procedure for
Transportation of Radioactive Materials
(AzSPU-HSSE-DOC-00115-2).
31st July 2010
Yuliy Zaytsev
Idrak Nazarov
Thorough revision require additional
(Safety &
(HSE MS Team
consultation with AzSPU RPA, hence
Compliance
Leader)
the document review requires to be
Manager)
extended
04th October 2010
Yuliy Zaytsev
John Elliott
Sub-paragraph 5.1.3.1 Monitoring of
(Safety &
(Senior HSE
Workers 3rd and 4th statement lines are
Compliance
Advisor)
updated
Manager)
Appendix A added new abbreviations
Appendix B updated contact details
information
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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Appendix A - Definitions & Abbreviations
Term
Definition
Absorbed Dose
Quantity of energy imparted by ionising radiation to unit mass of
matter such as tissue. Unit gray, Symbol Gy. Replaced the rad as unit
of absorbed dose.
1 Gy = 1 joule per kilogram.
1 Gy = 100 rads.
Activity
Measure of an amount of a radionuclide. Describes the rate at which
transformations occur in it. Unit becquerel. Symbol Bq. 1 Bq = 1
disintegration per second.
ALARP
As Low As Reasonably Practicable. Means taking every reasonable
effort to maintain exposures as far below the dose limits as is
achievable, while taking into consideration the trouble, time and
money needed to control it.
ALT
Azerbaijan Leadership Team
Alpha Radiation
Positively charged particulate radiation comprising 2 protons and 2
neutrons, emitted from some radioactive materials during radioactive
decay. It has low penetrating power and short range
(a few
centimetres in air). Not considered an external hazard but materials
that emit alpha radiation represent a significant internal hazard.
AzSPU
Azerbaijan Strategic Performance Unit
Becquerel
See Activity.
Beta Radiation
Negatively charged particulate radiation identical to an electron that is
emitted from some radioactive materials during radioactive decay.
Exposure to a large amount of beta radiation from external sources
may cause skin burns. Beta radiation is also presents an internal
radiation hazard. Thin sheets of low-density materials such as
aluminium or plastic may stop beta particles.
CAM
Contract Accountable Manager
Classified
/ Category
A
A Classified / Category A person is one who is likely to receive an
Person
effective dose in excess of 6 mSv per year, or an equivalent dose that
exceeds three-tenths of any relevant dose limit. A Classified
/
Category A person should be informed if he/she is so designated.
Classified / Category A persons should be over 18 years old and have
a health record certified by doctor confirming they are fit for the job.
Contamination
The contamination by any radioactive substance of any surface
(including the surface of the body or clothing) or any part of absorbent
objects or materials or the contamination of liquids or gases by any
radioactive substance.
Controlled Area
A controlled area is an area in which specific protective measures or
safety provisions are or could be required for:
controlling normal exposures or preventing the spread of
contamination during normal working conditions; and
Control Tier:
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preventing or limiting the extent of potential exposures.
cps
Counts per second
CTM
Compliance Task Manager
Curie
Former unit of Activity with symbol Ci. Replaced by the S.I. unit the
Becquerel. 1 Ci = 3.7 x 1010 Bq or 37 GBq.
DC&I
Drilling, Completions and Interventions
Decay
The process of spontaneous transformation of a radionuclide. The
decrease in activity of a radioactive substance.
Designated Area
Designated Areas include Controlled and Supervised Areas.
Disposal
In relation to radioactive waste, dispersal or emplacement in any
medium without the intention of retrieval.
Dose
General term for a dose quantity such as absorbed dose, equivalent
dose, and effective dose.
Dose Limit
Dose Limit in relation to persons of a specified class is the limit on
effective dose or equivalent dose in relation to a person of that class.
Dose Rate
Dose Rate, in relation to a place, is the rate at which a person or part
of a person would receive a dose of ionising radiation from external
radiation if he were at that place.
Effective Dose
The quantity obtained by multiplying the dose equivalents to various
tissues and organs by the tissue weighting factor appropriate to each
and summing the products. Unit sievert, symbol Sv. Frequently
abbreviated to dose.
ERP
Emergency Response Plan - Document describing the actions to be
taken in the event of a radiation incident or emergency, the purpose of
which is to restrict any exposure that arises from an accident both to
the employees themselves and to others, including emergency services
personnel, who may be affected by it. Also called Contingency Plan.
ERT
Emergency Response Team
Equivalent Dose
The quantity obtained by multiplying the absorbed dose by a
weighting factor to allow for the different effectiveness of the various
ionising radiations in causing harm to tissue. Unit sievert, symbol Sv.
Replaced the unit rem. 1 Sv = 100 rems.
External Radiation
External radiation, in relation to a person, is the ionising radiation
coming from outside the body of that person.
GBq
Gigabecquerel (109 Bq)
Gray
S.I. unit of Absorbed Dose. Symbol Gy.
Half Life
The time taken for the number of atoms in a radioactive material to
decay to half the original value.
HSE
Health, safety and environment
IAEA
International Atomic Energy Agency
Internal Radiation
Internal radiation, in relation to a person, is the ionising radiation
Control Tier:
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coming from inside the body of that person.
Ionisation
The process by which an atom or molecule acquires or loses an
electric charge. The production of ions.
Ionising Radiation
Radiation capable of causing ionisation either directly or indirectly
e.g. alpha and beta particles, neutrons, gamma rays and X-rays.
ISSOW
Integrated Safe System of Work
Site-Specific Instructions
Working procedures specific to a site where work with ionising
radiation is carried out. These may or may not include an Emergency
Response Plan.
LSA
Low Specific Activity. Term derived from transport legislation to
describe material with low specific activity that could include NORM.
MENR
Ministry of Ecology and Natural Resources
MES
Ministry of Emergency Situations
MPPU
Major Projects Performance Unit
Non-ionising radiation
Radiation that does not produce ionisation in matter. Examples are
ultraviolet radiation, light, infrared radiation, and radio frequency
radiation.
NORM
Naturally Occurring Radioactive Material. In the oil and gas industry
this is material that originates from reservoir rock that is associated
with production, maintenance and decommissioning activities.
Presents a risk to health and work with NORM and disposal of NORM
waste must be carried out in accordance with the applicable legislation
or standards.
OIM
Offshore Installation Manager
Overexposure
Any exposure of a person to ionising radiation to the extent that the
dose received by that person causes a dose limit relevant to that person
to be exceeded or causes a proportion of a dose limit relevant to any
employee to be exceeded.
PPE
Personal protective equipment
PSCM
Procurement and Supply Chain Management
PTW
Permit to Work
PU
Performance Unit
PUL
Performance Unit Leader
rad
Former unit of absorbed dose. Replaced by the gray (Gy).
1 rad = 0.01 Gy.
Radiation
Energy in the form of waves or particles originating from radioactive
materials or radiation generating equipment.
Radiation accident
Accident where immediate action would be required to prevent or
reduce the exposure to ionising radiation of employees or any other
persons.
RPA
Radiation Protection Adviser / Qualified Expert - Person or body
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
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appointed to give advice on radiation protection and compliance
matters.
RPO
Radiation Protection Officer - All third party contractors are required
to appoint a RPO to supervise their work.
RPS
Radiation Protection Supervisor - Person appointed to be responsible
for day-to-day supervision of work with ionising radiation and to
ensure that the radiation procedures and local rules are followed.
RP SPA
Radiation Protection Single Point Accountability
Radioactive
Exhibiting radioactivity.
Radioactive Waste
Material for which no further use is foreseen that contains or is
contaminated with radionuclides at concentrations greater than levels
set by the regulatory bodies.
Radioactivity
The phenomenon whereby atoms undergo spontaneous random
disintegration, usually accompanied by the emission of radiation.
Radionuclide
A species of radioactive atom.
Rem
Former unit of Equivalent Dose. Replaced by the S.I. unit the sieverts
(Sv).
RPA
Radiation Protection Advisor
SCSSIMP
State Committee for the Supervision of Safe Industrial and Mining
Practices.
Sealed Source
Radiation source containing a radioactive material and constructed to
ISO standards to prevent under normal conditions of use, dispersion of
the radioactive material into the environment.
Sievert
The S.I unit of both equivalent dose and effective dose. The symbol is
Sv. Sub multiples are milli Sieverts (mSv) and micro Sieverts (µSv).
One millisievert is one thousandth of one sievert and one micro sievert
is one thousandth on one millisievert.
SME
Subject Matter Expert
Source
of
ionising
Radioactive substance or device emitting or capable of emitting
radiation
ionising radiation
SPU
Strategic Performance Unit
SS
Safety Series
Supervised Area
Any area not already designated as a controlled area but where
occupational exposure conditions need to be kept under review even
though specific protection measures and safety provisions are not
normally needed.
Unsealed
Radioactive
Radioactive material not in the form of a sealed source, e.g. gas,
Materials
liquids or solid powder.
VP
Vice President
Written System of Work
A written method of work that permits non-classified workers who to
enter a controlled area.
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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X-rays
Penetrating electromagnetic radiation similar in nature to gamma
radiation but generated by electrical equipment.
Appendix B - Qualified Expert / Radiation Protection Adviser Contact
Details
AzSPU has appointed Tracerco Radiation Protection Advisory Services as their Radiation
Protection Adviser (RPA) (which is equivalent to the term Qualified Expert used by the IAEA
and the EC).
The first point of contact is Donald Urquhart, who is based in the Tracerco office in
Aberdeen, UK. However, all of the RPAs who are based either in the Aberdeen office, or the
Tracerco Billingham office, are able to advise on any issues affecting BP.
Contact details:
Aberdeen
Email
Telephone
RPAs
+44(0) 01224 650658 (direct)
Donald Urquhart
donald.urquhart@matthey.com
+44(0) 07875 384225 (mobile)
+44(0) 1224 650652 (direct)
Graham Wales
graham.wales@matthey.com
+44(0) 7764836669 (mobile)
+44(0) 1224 650653 (direct)
Bill Good
bill.good@matthey.com
+44(0) 7801662320 (mobile)
Billingham
Email
Telephone
RPAs
+44(0) 1642375462 (direct)
Andrew Smith
andrew.smith@matthey.com
+44(0) 7764290567 (mobile)
+44(0) 1642375463 (direct)
Nick Hutchison
nick.hutchinson@matthey.com
+44(0) 7919091388 (mobile)
+44(0) 1642375461 (direct)
Paul Warren
paul.warren@matthey.com
+44(0) 7889828968 (mobile)
Emergency Contact Details:
If none of the above can be contacted outside normal hours then call
+44(0) 1642 375500 and ask to speak to the duty RPA.
Postal Addresses
Aberdeen
Billingham
Office
Office
Tracerco
Tracerco Technology Centre,
Chattan Mews Office
Pavilion 10, The Moat,
18 Chattan Place
Belasis Hall Technology Park
Aberdeen
Billingham, Cleveland,
AB10 6RD
TS23 4AZ,
United Kingdom
United Kingdom
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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Appendix C - Controlled Area Handover Certificate
Controlled Area Handover Certificate
The work described below is to be carried out in a AzSPU Controlled Area. This
document is a formal record that responsibility for the Controlled Area is handed over
to the Contractor named below and that the Contractor agrees to accept
responsibility for ensuring compliance with any applicable legislation and local
rules/radiation procedures.
Installation:
Contractor:
Work Location:
Description of Work:
Commencement:
Date:
Time:
Completion:
Date:
Time:
Signed:
Contractor RPO
Print:
Date:
Signed:
AzSPU RPS
Print:
Date:
Control Tier:
2-AzSPU
Revision Date: October 04, 2010
Document No: AzSPU-HSSE-DOC-00058-2
Print Date: 2/1/2011
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Appendix D - Record of Entry into a Controlled Area
Date:
Site/Installation:
Work Location:
Average
Time of
Time of
Duration
Dose
Free of
RPO
Name
Company
Dose Rate
Entry
Exit
(Hrs) 1
(µSv)
Contamination?2
Initials3
(µSv/h)
Notes.
1 The duration of entry into the Controlled Area should be recorded to the nearest 0.5 hrs
2 All contamination must be removed before workers can leave the area
3 RPS or appointed deputy
40
Appendix E - Radiation Exposure Log
The purpose of the form is to allow AzSPU to make reasonable estimates of the doses
received by workers in AzSPU designated controlled areas. The form should be used for
workers who do not normally work in controlled areas, but are occasionally required to do so.
Workers who regularly work in controlled areas are subject to individual dose assessment and
will normally wear individual dosimetry.
This record must be retained in the Site Radiation Records
Name:
Company:
RADILOGICAL EXPOSURE
LOG
Company No.:
Calendar Year:
Average
Accum
Time
Time
Dose
Dose
ulated
Date
Location
RPS
In
Out
Rate
(µSv)
Dose
(µSv/h)
(µSv)
41
Appendix F - Radiation Monitoring
Introduction
The aim of this procedure is to give guidance on the proper use of radiation monitoring
instruments and the correct interpretation of results.
The radiation detection and measuring instruments are divided into two categories i.e.
contamination monitors and dose rate monitors.
Contamination monitors are used to detect and measure surface contamination i.e.
radioactivity on a surface or in a material. The monitors can be used to detect natural
radioactivity in materials i.e. Naturally Occurring Radioactive Material (NORM).
Dose rate monitors are used to measure the gamma dose rate arising from a source of
radioactive material or a radiation generator. The material may be in the form of a sealed
radioactive source such as a radiography source or a nucleonic source. Dose rates can also
sometimes be measured from NORM with a high specific activity and generally where there
are significant quantities of NORM, e.g. in a separator vessel or near bundles of contaminated
pipe/tubing.
Personnel
Only personnel who have received appropriate training may carry out radiation monitoring.
Appropriate training will include attendance at a RPS course, a NORM Awareness course, or
on the job training by the RPS. A record of on the job training will be kept by the Site RPS in
the Site Radiation Files or referenced therein.
Contamination Monitors
Contamination monitors typically incorporate a ratemeter and a detector. The detector type
determines the type of radiations that can be measured. The most common types of detectors
used to detect and measure NORM contamination are end window Geiger Mueller detectors
and scintillation detectors.
Monitors that use end window Geiger Mueller detectors are suitable for measuring alpha and
beta radiation, but are also sensitive to gamma radiation. Monitors that include probes with
Geiger Mueller detectors include the Tracerco T201 Monitor and Mini Monitor Series 900
rate meters with EP15 and EL probes.
Scintillation detectors are designed to detect specific types of radiation. Some detectors are
suitable for measuring only gamma radiation e.g. a Mini 900 Series Monitor with a 5.44A, or
44B probe. Other detectors are suitable for measuring alpha, beta or, in the case of a NE
PCM 5/1 ratemeter with DP2 probe, alpha and beta radiation.
It should be noted that the only monitor in common use that is intrinsically safe is the
Tracerco 201.
All of these instruments register in counts per second (cps). Unless done by the monitor,
calibration data is required to convert counts per second into Becquerels per square centimetre
(Bq/cm2) surface contamination. The conversion factor for particular radionuclides is found
on the instrument test certificate and sometimes on the instrument body.
42
The T201 is also calibrated in Bq/cm2 for selected radionuclides such as Radium-222 and
Lead-210, both in the wet and dry state. The monitor can be set to provide a direct readout in
Bq/cm2 for a selected radionuclide, while the analogue display reads c.p.s.
Checking a contamination monitor against a test disc
After each time a monitor is calibrated/tested, the RPS will check the response of the monitor
to the test disc and record the result in the Contamination Monitoring Log. If subsequent
checks against the test source deviate by 20% or more from this baseline value then the
monitor should be sent for retest.
Pre-use Checks and Function Tests
Prior to carrying out any measurements, the following checks must be carried out:
Prior to switching on, check the zero setting (analogue displays only) i.e. ensure the
needle sits on 0.
For instruments with a H.V. setting, check that the setting corresponds to the setting on
the test certificate.
Check the meter and probe (especially the detector) for signs of damage
Ensure the instrument is in calibration i.e. it has been tested in the last 12 months and
there is a valid test certificate
Where applicable, ensure that the rate meter and probe combination is as stated on the test
certificate
Switch to the „battery check‟ setting (the T201 performs a self check) and leave for 20s. If
the needle starts to drop back then replace the battery following the manufacturers
instructions.
Remove any protective caps from the detector and check the response to a test source is
within
20% of the value after retest and record the result on the Contamination
Monitoring Log in the Procedures for Work with NORM.
Contamination Monitoring
Carry out and record a backg2round check. This should be carried out away from sources
of radiation and should normally be no more than a few c.p.s.
Angle the detector face as close as possible to the surface being checked.
Hold the face of the detector approximately 2mm away from the surface, taking care not
to contaminate the detector by touching the surface.
Move the probe slowly e.g. 25mm/second, across the surface taking care not to damage
the window of the detector on any sharp objects.
To determine whether a monitor is detecting contamination on an external or internal
surface of an item, the plastic cap should be placed on the detector. If the reading
decreases, then there is external contamination present. If there is no cap available then
another suitable absorber could be used e.g. a piece of plastic, a few mm thick.
NORM contamination is considered to be present where there is a sustainable rise above
the instrument's normal backg2round.
General Points on Use
Keep the monitor clean particularly the probe face, where deposits of contaminated
material may increase the monitor's normal backg2round. Take great care when
attempting to clean the face of a probe.
Renew batteries before the indicator falls into the „low battery‟ area
43
With detachable probes, ensure the connection is tight and the cable cannot be kinked or
caught in obstructions.
Contamination monitors that are not intrinsically safe should not be used in an area where
recently broken containment has taken place. If a risk of flammable material is present, a
sample of the contaminant should be removed from the vessel and measured outside the
area of risk.
Dose Rate Monitoring
Dose rate monitors are generally used to measure gamma dose rate. Neutron monitors are also
used where neutron sources or neutron generators are used.
The dose rate is the rate at which a dose of radiation is received over a given amount of time.
The unit of dose is the Sievert (Sv), however, as this is a very large dose, dose rate meters
usually measure micro Sieverts (Sv) or milli Sieverts (mSv). The unit of dose rate is
therefore usually expressed in micro Sieverts per hour (Sv/h) or milli Sieverts per hour
(mSv/h).
Typical dose rate meters include the Gammatrol PRI-190 or the Tracerco T202, which
measure gamma radiation dose rate, both of which are intrinsically safe.
Pre-use Checks and Function Tests
Prior to switching on, check the zero setting (monitors with analogue displays only) i.e.
ensure the needle sits on 0.
Check the monitor for signs of damage
Check the battery (self test carried out by the Gammatrol and T202)
Ensure the instrument is in calibration i.e. it has been tested in the last 12 months and
there is a valid test certificate
Dose rate monitoring
Switch on, away from sources of radiation if possible
If applicable, select the lowest (i.e. most sensitive) range, which is usually 0-10 µSv/h
Carry out a measurement with the front of the monitor pointed at the source of radiation
Move the monitor around slowly to observe any increase or decrease in measurement
Change the range if necessary
Record the result
General Points on Use
Renew batteries before the indicator falls into the „low battery‟ area
Measurements of dose rate around nucleonic devices should be made at approximately 30
cm from the nucleonic, the detector or from vessel walls; this measurement indicates the
„whole body dose rate‟.
Measurement of dose rate at closer than 30 cm is generally an indication of the dose rate
for extremities e.g. hands and forearms.
44
Appendix G - Site Radiation Monitoring Equipment Register
Insert Site details here has the following radiation monitoring equipment:
DOSE RATE MONITORS
Reason for
Re-
Serial
Last
Make
Model
Location
Test (e.g.
test
Comments
Number
Tested
Routine)
Due
CONTAMINATION MONITORS
Reason for
Re-
Serial
Last
Make
Model
Location
Test (e.g.
test
Comments
Number
Tested
Routine)
Due
MONITOR TEST DISCS / SOURCES
Next
Serial
Leak
Type
Activity
Location
Test
Comments
Number
Tested
Due
45
Appendix H - Critical Examination Checklist
The following checklist will be completed by the Site RPS prior to accepting handover of
responsibility for a nucleonic gauge from the Contractor installing the gauge.
Checklist
Yes
No
Is the gauging device securely mounted?
Is the source housing mounted such that it is not possible to get access to the
primary radiation beam?
Does the source housing contain a radiation trefoil sign?
Is there a source detail plate fixed to the source housing?
Does the source detail plate contain details of source type (i.e. radionuclide),
source activity and serial number?
Do the source serial number and activity details match those in the Contractors
source documentation?
Where appropriate, is the source holder secure and padlocked in place?
Where appropriate, does the shutter mechanism operate satisfactorily?
Is the shutter status (i.e. „open‟ or „closed‟) clearly indicated?
With the source(s) exposed, are accessible dose rates less than 7.5 Sv/h for
whole body exposure (i.e. at 30 cm from source container, the vessel and the
detector) and less than 75 Sv/h for exposure to hands, forearms or feet? Also,
is the dose rate at the surface of the source housing less than 100 Sv/h and
less than 3 Sv/h at 1 m (Ref. [7], Clauses 2.5 and 4.5)
For vessel-mounted (as opposed to pipe-mounted) devices, are radiation-
warning signs posted at all entrance points to the vessel?
Is a Leakage Test Certificate available for the source(s) and has the source(s)
been tested in the last two years?
Comments
Checks carried out by:
Name:
…………………………..
Signature:
…………………………..
Date:
…………………………..
Completed forms should be field in the Site Radiation Records
46
Appendix I - Radioactive Source Accountancy, Monitoring and Safety Checks
Source Type:
Location:
Activity:
Use:
Serial No.:
Instrument I.D.:
Max. Dose
Shutter
Rate (Sv/h)1
Condition of
Warning
Date
Open /
Comments
Signed
Gauge4
signs5
Housing2
Detector2
Closed3
NOTES
1.
Measurements should only be carried out by person(s) who have received appropriate training; this is not necessarily the RPS.
2.
If a measurement cannot be made at the housing or detector, then record the location that the measurement is made under “Comments”.
3.
The status of the shutter when measurements are made should be recorded i.e. either open or closed. Alternatively, if the source (or sources) is located in a dip pipe then
record whether it is retracted or not.
4.
Check for signs of wear and tear or damage: if maintenance is required then record this under “Comments”.
5.
Check warning signs on the gauge and on the vessel entry points. This should include a check on the source detail plaque and on the shutter status indication.
47
Appendix J - Leakage Test Method
The RPS, or an Authorised Person who has received appropriate training, will carry out the
test. Alternatively, the test may be carried out by the Radiation Protection Adviser (RPA)
during the annual audit.
The leakage test does not require direct access to the source. At no time will the source or
source holder be removed from the source container.
Kit required
Swabs and tubes supplied by Tracerco (N.B: As an alternative to the Tracerco swab, a
small piece of cotton wool and a re-sealable bag may be used).
Small container of water or isopropyl alcohol e.g. 100ml.
Re-sealable bag.
Pen.
Disposable gloves.
Contamination monitor.
Radiation dose rate monitor.
Procedure
Carry out radiation dose rate measurements around the source housing to ensure that whole
body dose rates are less 7.5 µSv/h and extremity (hands, feet and forearms) dose rates are less
than 75 µSv/h.
Put on the gloves and then moisten a swab with water. Wipe the moistened swab over all
areas that could reasonably be expected to reveal any leakage of the source i.e. at the shutter
mechanism and where the source holder is fitted into the source container.
For interface gauges, the rear cap should be removed and a wipe made where the wire or
source rod passes through the shutter mechanism. (The same wipe can be used). For Profiler
gauges a wipe should be made where the source control handle fits into the gauge.
The swab should then be placed into the small plastic tube and the tube sealed. The tube
should then be placed in the plastic bag. The bag should then be sealed and the contents
should be checked for gross contamination using the contamination monitor on the c.p.s
setting.
Assuming no contamination is found (if contamination is found, follow the procedures
overleaf) the gloves may be removed. The bag should be marked with the following details:
Date.
Radionuclide.
Identification of the source or sources (in the case of a Profiler gauge the gauge number
may be used as an identifier).
The „Request For Analysis Form‟ and the „Request for Leak test Analysis Form‟ on the
be completed and the forms and wipes sent to the Tracerco laboratory:
Chris Pollin / Karen Waterman, Tracerco (Pavilion 10), PO Box, Belasis Technology Park,
Billingham, Cleveland, TS23 1LB, UK.
48
Procedure in the event of contamination being detected
Do not panic. Assume that the person performing the leak test may be contaminated,
although this is highly unlikely.
Summon help to inform the RPS immediately.
The RPS should initiate the contingency plans for leaking source (see AzSPU Radiation
Contingency Plan, AzSPU-HSSE-DOC-00086-2).
Seal the wipe within another bag to minimise the risk of spreading any contamination.
Appendix K - Procedure for Isolating and De-isolating Sources in Dip-
pipes
Isolation and De-isolation kit
A
4mm Allen (Hex Head) Key
B
Retaining Padlock, Pin or Wire (to pass through 3/16" holes in source capsule and
containment plate)
C Padlock for shutter mechanism (usually small D4)
D Radiation Dose Rate Monitor.
Radioactive Source Isolation Procedure
1. Remove the rear cover by unscrewing the four Allen (Hex Head) screws; retain the
screws.
2. Pull the end of the extension rod/cable
(which will be ill be visible in centre of
containment plate) to its full extent
(NOTE: rod/cable will be at vessel operating
temperature
- wear gloves). The source capsule cannot be withdrawn past the
containment plate.
3. Close the shutter by pushing in or turning to "CLOSED" position. Padlock shutter
mechanism shut at this point using item C (above).
4.
3/16" dia. holes in source capsule and retaining lug on containment plate should be
aligned. Place item B (above) through these holes.
5. Unscrew extension rod/cable from source capsule and retain for future use.
6. Replace the rear cover using the 4 Allen (Hex Head) screws.
7. Use the Radiation monitor to observe radiation levels both at the source head and
detector. No radiation should be detected at the detector after the source has been
retracted into the source head.
8. Add notice to shielded container indicating source isolation.
Note! All padlock keys and extension rods/cables should be kept in a secure or controlled
system. Extension rods should be labelled to identify the gauge that they have been removed
from.
De-isolation Procedure
DO NOT UNLOCK OR OTHERWISE ADJUST THE CONTAINER SHUTTER
MECHANISM BEFORE STEP 5 BELOW.
1. Remove the rear cover by unscrewing the four Allen (Hex Head) screws; retain the
screws.
49
2.
The end of the radioactive source connector will be in view. It will probably be locked
using a small padlock (item B) to a small locking tab attached to the capsule containment
plate. If a lock is not used, the capsule may be loosely wired to the locking tab. DO NOT
remove the padlock or fixing wire yet.
3.
A rigid extension rod or flexible cable assembly is used to correctly position the source
capsule at the end of the internal dip-pipe in the vessel. This rod/cable will have been
removed when the source was isolated; it should be labelled to identify the gauge to
which it fits. Attach this rod or cable assembly to the threaded rear of the source
connector, making sure that it is tightly screwed into position. It is quite safe to touch the
end of the source connector.
4.
Unlock and remove the padlock or fixing wire attaching the source connector to the
containment plate.
5.
Unlock and remove the padlock (item C) holding the shutter mechanism in the SHUT
position. Pull or rotate the shutter mechanism to the „OPEN‟ position (the method of
opening the shutter depends on the shielded container type). This removes an internal
shield (item 2) within the shielded container and allows passage of the source capsule into
the vessel dip-pipe. The shutter may be wired (NOT locked) in the open position to
prevent accidental closure.
6.
Push the extension rod/cable gently so that the source capsule enters the vessel dip-pipe.
Ensure that the source assembly does not catch any internal edges within the dip-pipe.
Move the source assembly gently back and forth if this happens so that any internal
obstructions are bypassed. When in the correct position, the source capsule should touch
the end of the internal dip-pipe and cannot be pushed further into the dip-pipe (a slight
flexing will be encountered if flexible cables are used. The assembly should reach a
"rest" position with the source capsule at the end of the dip-pipe). Once in position,
approximately 50mm of extension rod should protrude at the rear of the shielded
container.
7.
Replace the rear cover using the 4 Allen (Hex Head) screws. The back cap will ensure
that the entire assembly is held securely in the correct operating position. Extension
rods/cables are cut to length at commissioning to ensure this.
8.
Add notice to shielded container indicating source condition (de-isolated).
Appendix L - Procedure for Isolating and De-isolating Profiler Sources
Isolation and de-isolation kit
Padlock and key
Soft Fastening e.g. tie wrap
Isolation Procedure
1. Push down on the lever on the neck of the profiler to the indicated „closed‟ position. This
action brings the sources behind a shield, thereby reducing the surface dose rate on the
internal dip pipe.
2. Insert a padlock in the hole provided and lock it.
Comments
Complete closure must be confirmed on vessel entry by the use of an appropriate radiation
monitor
This padlock and key will be securely retained
50
NOTE! The source isolation lever should never be locked in the „open‟ position. A „soft‟
fastening, such as a wire or clip could be used to prevent inadvertent closure.
De-isolation Procedure
1. Remove padlock
2. Raise the lever on the neck of the profiler to the indicated „open‟ position.
3. Apply soft fastening if required.
51
Appendix M - Contractors Checklist for Contractors Using Radioactive
Materials on AzSPU Sites
Site Name:
Contractor:
Contractor Address:
Contractor’s RPA:
Contractor’s Site RPO (RPS):
Nature of work:
Source type:
Serial No.:
Activity:
Source Storage Location:
Checklist
Yes
No
N/A
Is the transport container in good condition?
Is the container labelled properly?
Do the measured dose rates correspond to the transport labels?
Does the Contractor have a valid Special Permit for work with this type
of radiation and is it available?
Are there sufficient RPOs for the work?
Do they have adequate dosimetry?
Are there Radiation Procedures and / or Local Rules available?
Are Emergency Response Plans available?
Is the equipment listed in the emergency kit available and operating?
Are suitable and sufficient Controlled Area signs available?
Are sufficient barrier materials available?
Are radiation-monitoring instruments appropriate to each type of
radiation to be used available?
Gamma Dose Rate Meter (x 2 for radiography)
Neutron Dose Rate Meter
Contamination Meter
Are the instruments functioning?
Are test certificates available for the meters?
52
Checklist
Yes
No
N/A
Does the Contractor have documentation with details of the source(s)
Are there current leak test certificates available for all sources?
Does the Contractor have a source movement / accounting record?
Signed AzSPU RPS
Print:
Date:
If the answer to any of the above is “No” then the OIM should be notified and alternative
arrangements must be made that provide the same level of control or safety. The OIM will
decide whether or not to allow the work to go ahead and record his decision below, noting
any alternative arrangements that have been made. The AzSPU Radiation Protection (RP)
SPA and the Radiation Protection Adviser (RPA) should be contacted for advice if necessary.
OIM Comments:
Signed AzSPU (OIM):
Print:
Date:
53
Appendix N - Site Mobile Source Register
Site / Installation:
Physical
Source
Transferred to?
Source
Source
Ref
Service
Nuclide
Activity
form e.g.
Serial
Storage
e.g. beach, well
Audit
Arrival
Transfer
Signed
No.
Company
e.g. 137Cs
(MBq)
sealed,
Number
Location
number, rig
Date
Date
Date
gas, liquid
or I.D.
transfer1
Note.
1. If any mobile sources such as well logging or depth correlation markers are left in a well, details should be recorded here and then added to the Site Inaccessible Source
Register.
54
Appendix O - Site Inaccessible Source Register
Site / Installation:
Date Source
Physical
Ref
Service
Nuclide
Activity
Source Serial
Location of Inaccessible
Audit
Became
form e.g.
Signed3
No.
Company
e.g. 137Cs
(MBq)
Number or I.D.
Source2
Date
Inaccessible1
sealed, liquid
Note. 1. The corresponding record in the Site Mobile Source Movement Register must be completed
2. Insert details of the location where the source is installed. For abandoned logging sources, well number, sidetrack number, depth. For other sources, as much
information as possible
3. In the case of abandoned logging sources, the register should only be signed once a wellhead notice indicating the presence of down-hole sources is in place.
55
Appendix P
References
Azerbaijan Republic Law on Public Radiation Safety No 4231Q as of January 30,
1997
International Atomic Energy Agency in Safety Series 115, Radiation Protection
Convention, 1960
Resolution No.
134 On approval of the Rules on Form and Completion of
Radiological-Hygienic Passports of Territories, Enterprises and Organisations and the
Rules of Recordation and Control Over Individual Ray Doses, August 25, 1999
The Cabinet Of Ministers Of The Azerbaijan Republic Decision No. 10 Baku City,
27 January 2000 On Approval of the Rules for Carriage of Dangerous Goods by Road
Law of the Azerbaijan Republic, № 913-IГ. On joining the European
Agreement (30 September 1957 )on the International Carriage of Dangerous
Goods by Road (ADR) and the Protocol on signing it
Cabinet of Ministers of the Azerbaijan Republic Resolution No 75 On
approving the Regulations for transportation of hazardous goods by maritime
transport
International Air Transport Association technical Instructions for the
Transport of Dangerous Goods by Air (IATA), 2009
International Maritime Dangerous Goods Code (IMDG), 2009 (with the
amendment of 34-08)
56
AzSPU Procedure for Transportation of Radioactive Materials
Page 1 of 24
AzSPU Procedure for Transportation of
Radioactive Materials
AzSPU-HSSE-DOC-00115-2
Authority:
Yuliy Zaytsev (AzSPU
Custodian:
Hazardous Materials TA
Safety & Compliance
Manager)
Scope:
AzSPU
Document
AzSPU HSSE MS Document
Administrator:
Coordinator
Issue Date:
7th October, 2009
Issuing Dept:
AzSPU HSSE
Revision Date:
1st July, 2010
Control Tier:
2
Next Review
7th October, 2010
Date:
Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE
CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT
AzSPU Procedure for Transportation of Radioactive Materials
Page 2 of 24
TABLE OF CONTENTS
1.
PURPOSE/SCOPE
3
2.
DEFINITIONS
3
3.
GENERAL REQUIREMENTS
4
4.
KEY RESPONSIBILITIES
6
5.
PROCEDURE / PROCESS
9
5.1 TRANSPORTATION OF RADIOACTIVE SOURCES
9
5.1.1 Transportation of Radioactive Sources Offshore
9
5.1.2 Transportation of Radioactive Sources Onshore
11
5.2 TRANSPORTATION OF NORM CONTAMINATED EQUIPMENT / WASTE
12
5.3 TRANSPORTATION OF NORM CONTAMINATED SAMPLES
13
5.4 TRAINING
14
5.5 PERMITTING / LICENSING REQUIREMENTS
14
6. KEY DOCUMENTS/TOOLS/REFERENCES
14
APPENDIX A - REQUIREMENTS FOR CATEGORISING, PACKING, MARKING, AND LABELLING
RADIOACTIVE MATERIALS FOR TRANSPORTATION
16
APPENDIX B - DANGEROUS GOODS DECLARATION FORM - COMPLETED FOR NORM
CONTAMINATED EQUIPMENT / WASTE (SEE RED TEXT)
22
APPENDIX C - RADIATION PROTECTION ADVISER / QUALIFIED EXPERT (RPA) CONTACT
DETAILS
22
Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
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AzSPU Procedure for Transportation of Radioactive Materials
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1.
PURPOSE/SCOPE
The intent of this procedure is to ensure a systematic approach to the transportation of
radioactive material
(to and from onshore and offshore AzSPU facilities) and to provide
requirements for permitting, packaging, labeling, documentation, and chain of custody.
Radioactive material encompasses radioactive sources, NORM contaminated equipment, NORM
waste (e.g. LSA scale), and NORM samples.
This controlled procedure applies to AzSPU Operations PUs and Projects engaged in the drilling,
production, and/or transportation of oil and gas (including support activities), and construction
activities when working with radioactive materials in Azerbaijan. Contractors working on
AzSPU owned or operated sites/installations are also required to align with this procedure.
This procedure does not replace, not should it conflict with, the AzSPU Procedure for
Management of Radioactive Materials and Radiation Generators (AzSPU-HSSE-DOC-00058-2).
Any form of deviation from this procedure, including but not limited to site-specific instructions,
shall be requested and authorised in accordance with the AzSPU Deviations Procedure (AZSPU-
HSSE-DOC-00011-2).
Revision of this procedure and the operational controls detailed therein will be in accordance
with the AzSPU HSSE Document Management Procedure (AzSPU-HSSE-DOC-00025-2).
2.
DEFINITIONS
A full glossary of terms related to radiation and radioactive materials is provided in Appendix A
of the AzSPU Procedure for Management of Radioactive Materials and Radiation Generators
(AzSPU-HSSE-DOC-00058-2).
Additional definitions specific to this procedure are included here:
Consignee
A person or organisation that receives a consignment.
Consignor
A person or organisation that prepares a consignment for transport.
Fixed
Contamination other than „non-fixed contamination‟ (see definition
Contamination
below).
Low toxicity alpha
Natural uranium; depleted uranium; natural thorium; uranium-235 or
emitters
uranium-238; thorium-232; thorium-228 and thorium-230 when
contained in ores or physical and chemical concentrates; or alpha
emitters with a half-life of less than 10 days.
Non-fixed
Contamination that can be removed from a surface during routine
contamination
conditions of transport.
Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
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Page 4 of 24
Overpack
An enclosure such as a box or bag which is used by a single consignor
to facilitate as a handling unit a consignment of one or more packages
for convenience of handling, stowage and carriage.
Package
The packaging with its radioactive contents as presented for transport.
Packaging
The assembly of components necessary to enclose the radioactive
contents completely, which may consist of one or more receptacles,
absorbent materials, spacing structures, radiation shielding etc. The
packaging may be a box, drum or similar receptacle, or may also be a
freight container, tank or intermediate bulk container.
Radioactive material
Any material containing radionuclides where both the activity
concentration and the total activity in the consignment exceed specified
values (see Table 1).
Special form
Either an indispersible solid radioactive material, or a sealed capsule
radioactive material
containing radioactive material.
Specific activity
The specific activity of a radionuclide shall mean the activity per unit
mass of that nuclide. The specific activity of a material shall mean the
activity per unit mass of the material in which the radionuclides are
essentially uniformly distributed.
Transport Index
The Transport Index assigned to a package, overpack or freight
container, or to unpackaged LSA-I or SCO-I, shall mean a number that
is used to provide control over radiation exposure. The number has no
units and is derived by dividing the dose rate, measured in µSv/h, at 1 m
from a package by 10.
3.
GENERAL REQUIREMENTS
General requirements pertaining to radiation safety are detailed in Section 3.1 of the AzSPU
Procedure for Management of Radioactive Materials and Radiation Generators (AzSPU-HSSE-
DOC-00058-2).
In addition the following legislation is also considered applicable to this procedure:
International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive
Material, IAEA Safety Standards Series No. TS-R-1.
Road transport: Decree of the Cabinet of Ministers of the Azerbaijan Republic No. 10, 27
January 2007, On Approval of the Rules for Carriage of Dangerous Goods by Road. The decree
implements most of the provisions of the European Agreement on the Carriage of Dangerous
Goods by Road (ADR).
Sea transport: Current edition of the International Maritime Dangerous Goods Code (IMDG
Code).
Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
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Page 5 of 24
Air transport: Current edition of the International Air Transport Association Technical
Instructions for the Transport of Dangerous Goods by Air (IATA).
Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
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AzSPU Procedure for Transportation of Radioactive Materials
Page 6 of 24
Radioactive Material & Exemptions:
The transport legislation defines radioactive material as that which exceeds a specified activity
concentration and total activity. Examples of exemption levels for some commonly encountered
radioactive materials are provided in Table 1.
Table 1: Radionuclide Exemption Levels
Activity concentration for an
Activity limit for an exempt
Radionuclide
exempt material (Bq/g)
consignment (Bq)
Americium-241
1
10,000
Bromine-82
10
1,000,000
Caesium-137
10
10,000
Carbon-14
10,000
10,000,000
Cobalt-60
10
100,000
Hydrogen-3
1,000,000
1,000,000,000
Iridium-192
10
10,000
Lead-210
10
10,000
Polonium-210
10
10,000
Radium-226
10
10,000
Radium-228
10
100,000
Material that does not exceed the activity concentrations in Table 1 can be classed as
Exempt and can be transported in accordance with AzSPU’s existing transportation
practices.
NB: NORM materials encountered in the oil and gas industry are frequently found to be Exempt
from the transport legislation. However, the activity concentration of a radioactive material can
only be determined by analysis of the material at a suitable laboratory.
4.
KEY RESPONSIBILITIES
A full description of the responsibilities with regard to radiation protection is provided in Section
4 of the AzSPU Procedure for Management of Radioactive Materials and Radiation Generators
(AzSPU-HSSE-DOC-00058-2). A summary of key responsibilities directly applicable to this
procedure are provided below:
Site Manager / OIM
The Site Manager / OIM is accountable for providing authorization for dispatch of radioactive
sources to their site / facility.
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Supply Base / HSE Personnel
Responsible for ensuring that:
Trucks and drivers arriving at the Supply Base are in compliance with legislative
requirements, prior to allowing entry.
Shipping containers are intact and fit for purpose, and that labeling, placarding, and
documentation are in accordance with applicable legislation (see Appendix A).
Radioactive sources are transported together with all accompanying documentation and
monitoring equipment (i.e. the load must not be split between vessels).
Deck Forman
Responsible for ensuring the safe lifting of radioactive sources onboard the Installation and
informing / consulting with contractor, or site RPS, about the placement and location of the
sources.
Site Radiation Protection Supervisor (RPS)
With respect to the transportation of contractor owned radioactive sources the RPS is responsible
for:
Inspecting packages or containers containing radioactive sources, ensuring that they are
undamaged, and that the surface dose rate and Transport Index are correct
(in
collaboration with the contractor RPO).
For identifying designated storage areas for radioactive sources and establishing
controlled / supervised areas (if required).
Maintaining Site Radiation Records
(completing Contractor Checklist, Site Mobile
Register, Critical Examination Checklist, etc).
Reviewing contractor‟s arrangements for accounting for radioactive sources.
With respect to the transportation of AzSPU owned NORM contaminated equipment / waste the
RPS is responsible for:
Ensuring that the contaminated equipment / waste is categorized, packed, marked and
labeled appropriately (see Appendix A), and that the Dangerous Goods Declaration is
completed (see Appendix B).
For collecting samples of NORM, monitoring their contamination levels, preparing them
for transportation, and arranging for them to be couriered to the Tracerco laboratory.
Contacting the AzSPU RP SPA for advice on cleaning / disposal of contaminated
equipment / waste, prior to it being shipped from the facility.
AzSPU Radiation Protection Single Point Accountability (AzSPU RP SPA)
Responsible for maintaining a proper communication flow between the AzSPU RPA (UK based)
and the Site Radiation Protection Supervisors (RPSs).
Control Tier: 2
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Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
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AzSPU Radiation Protection Advisor (RPA)
AzSPU retains by contract and appointment a RPA to provide the AzSPU with expert advice on
radiation safety and compliance matters. The RPA reports to the AzSPU Safety & Compliance
Manager and works directly with the AzSPU RP SPA.
In terms of this procedure, the RPA will be consulted with respect to the following:
Cleaning / disposal options for NORM contaminated equipment / waste, based on the
results of sampling and analysis.
Provision of instructions to drivers regarding accidents and emergencies (where AzSPU
is the consigner).
Contractors
All third party contractors transporting radioactive materials to / from AzSPU sites are required
to work in accordance with this procedure, and in compliance with applicable national and
international legislation.
5.
PROCEDURE / PROCESS
5.1
TRANSPORTATION OF RADIOACTIVE SOURCES
5.1.1 Transportation of Radioactive Sources to / from Offshore Facilities
Before a Contractor brings a radioactive source onto an offshore facility, he will notify the OIM,
the site RPS, the Supply Base, and the sponsoring department representative at least 24 hours
prior to dispatch. The following information will be provided:
Number, type and size of sources.
Name of vessel/transport company.
Dispatch date and time and estimated time of arrival.
Type and ID number of transport container.
Transport Index.
The OIM is responsible for providing authorization for dispatch.
The contractor will ensure that the radioactive substances are categorized, packed, marked and
labeled appropriately (see Appendix A). The contractor will also complete and sign a Dangerous
Goods Declaration.
The contractor will also provide test certificates for packages used for shipping of radioactive
materials when requested by a site RPS.
Once authorization has been obtained from the OIM the contractor delivers the radioactive
source to the Supply Base.
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Supply Base Operations/HSE personnel will check that the transport arrangements are in
compliance with applicable legislation for transportation of radioactive sources (see Section 5.5).
Trucks or drivers not in compliance with legislative requirements will not be allowed to enter the
site.
Once sources are accepted onto the site Ops/HSE personnel will check if the shipping container
is intact and fit for purpose, and that labeling, placarding, and documentation are in accordance
with applicable legislation (see Appendix A).
Any shipping containers carrying radioactive source(s) will be loaded to the Supply Vessel as a
last item before dispatch and secured with deck straps for transit. The shipping manifest is
completed by the Supply Base Materials / Logistics Coordinator.
It should be noted that radioactive source(s) must always be transported offshore together with
all accompanying documentation and monitoring equipment. Splitting of equipment onto
different vessels has the potential to result in business value loss (as the work cannot be carried
out on the facility until all equipment and documentation received) and unsafe operations (e.g.
lack of radiation monitoring equipment in case of incident with radioactive source on vessel).
Upon arrival offshore, the Deck Foreman will place the radioactive source container into a
designated storage area previously agreed between the site RPS and contractor RPO. Where such
arrangements have not been previously agreed, the Deck Foreman will contact the site RPS or
contractor RPO before unloading the source container from the vessel.
The site RPS and contractor RPO will inspect packages or containers containing radioactive
material and ensure they are undamaged, and that the surface dose rate and Transport Index are
correct, i.e. as described on the transport documents and the package labels. Any anomalies will
be addressed by the contractor RPO. A controlled area / supervised area will be set up around the
source, if required (see Section 5.1.1 of the AzSPU Procedure for Management of Radioactive
Materials and Radiation Generators (AzSPU-HSSE-DOC-00058-2)).
Where a contractor does not accompany his radioactive source to site, the contractor will
endeavour to have an RPO on the site prior to the source arriving. By prior arrangement and
agreement, the site RPS may receive sources on behalf of the contractor. The site RPS will then
carry out the checks described above.
The site RPS will complete the Contractor Checklist (Appendix M of the AzSPU Procedure for
Management of Radioactive Materials & Radiation Generators (AzSPU-HSSE-DOC-00058-2))
prior to starting any on-site work with the radioactive source.
The site RPS will also update and maintain the Site Mobile Source Register (Appendix N of the
AzSPU Procedure for Management of Radioactive Materials & Radiation Generators (AzSPU-
HSSE-DOC-00058-2)) in order to record radioactive sources arriving on site and those leaving.
Contractors must carry out and record an accounting check for radioactive materials on a daily
basis. The contractor is responsible for ensuring that that these checks are carried out and the
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results recorded. The site RPS will review the contractor‟s arrangements for accounting for
radioactive substances on a regular basis, although the results of the RPS‟s checks do not need to
be recorded.
If the radioactive source is installed on the facility (e.g. installation of a nucleonic device) a
Critical Examination Checklist
(Appendix H of the AzSPU Procedure for Management of
Radioactive Materials & Radiation Generators (AzSPU-HSSE-DOC-00058-2)) will be completed
by the site RPS prior to AzSPU accepting responsibility for the device.
On completion of the scope of work, and prior to leaving the site, the contractor will ensure that
his sources are categorized, packed, marked and labeled appropriately (see Appendix A) and that
a Dangerous Goods Declaration has been completed. The Platform Materials
/ Logistics
Coordinator will complete the shipping manifest, using the contractor‟s Dangerous Goods
Declaration and with the assistance of the contractor RPO (if required).
In the event that the contractor leaves the site prior to dispatch of their radioactive source there
must be a formal handover of responsibility for the source between the contractor and the site
RPS and the contractor must present their completed documentation for transport. The site RPS
is then responsible for the security and accounting of the source. Radioactive sources must not be
left on site unless these, or suitable alternative arrangements have been made.
Prior to shipping the radioactive source the Platform Materials / Logistics Coordinator will
ensure that 24 hours notification has been sent to Supply Base and to the contractor.
The Supply Base liaises with the contractor to enable the contractor to have transport available to
collect the source at an appropriate time. The source is then transported on to the contractor‟s
premises.
As a general rule, sources used offshore will normally be back loaded if they will be redundant
for 7 days or more.
NB: Sources can be transported between offshore facilities but the same documentation that
would be required to send the sources onshore must be completed.
5.1.2 Transportation of Radioactive Sources to / from Onshore Facilities
The requirements outlined above for offshore transportation of radioactive sources also apply to
transportation of radioactive sources to AzSPU‟s onshore facilities. In this case, however,
radioactive sources are delivered directly from contractor owned storage facilities to AzSPU
facilities (without passing through the Supply Base). The contractor will notify the Site Manager,
site RPS, and the sponsoring department representative at least 24 hours prior to dispatch. The
Site Manager is responsible for providing authorization for dispatch.
The contractor will ensure that the radioactive substances are categorized, packed, marked and
labeled appropriately (see Appendix A). The contractor will also complete and sign a Dangerous
Goods Declaration.
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The contractor will also provide test certificates for packages used for shipping of radioactive
materials when requested by a site RPS.
On arrival at the facility, the radioactive source container will be placed in a designated area
previously agreed between the site RPS and contractor RPO. The site RPS and contractor RPO
will then inspect the packages, or containers containing radioactive material, and ensure they are
undamaged, and that the surface dose rate and Transport Index are correct, i.e. as described on
the transport documents and the package labels. Any anomalies will be addressed by the
contractor RPO.
Sources that are used onshore may be stored onsite temporarily, without being placed in a store
area, provided they are accompanied at all times.
The site RPS will be responsible for completing the Contractor Checklist prior to work with the
radioactive source, for updating and maintaining the Site Mobile Register, and for completing the
Critical Examination Checklist if radioactive sources are installed on the facility.
Contractors must carry out and record an accounting check for radioactive materials on a daily
basis. The contractor is responsible for ensuring that that these checks are carried out and the
results recorded. The Site RPS should review the contractor‟s arrangements for accounting for
radioactive substances on a regular basis, although the results of the RPS‟s checks do not need to
be recorded.
On completion of the scope of work, and prior to leaving the site, the contractor will ensure that
his sources are categorized, packed, marked and labeled appropriately (see Appendix A) and that
a Dangerous Goods Declaration is completed.
As a general rule, mobile sources are not stored at AzSPU onshore facilities. They are returned to
the contractor‟s storage facilities at the end of the work day.
5.2
TRANSPORTATION OF NORM CONTAMINATED EQUIPMENT / WASTE
In terms of NORM contaminated equipment and waste it is the site RPS‟s responsibility to
ensure that the radioactive substances are categorized, packed, marked and labeled appropriately
(see Appendix A). The site RPS will also complete and sign a Dangerous Goods Declaration
(Appendix B contains a Dangerous Goods Declaration Form already completed with the correct
UN number, proper shipping name, radionuclide information, activity, form, hazard category and
package classification for NORM contaminated equipment / waste - see red text).
Generally, NORM contaminated equipment will not be transported from site until sampling and
analysis has been carried out and advice received from the RPA. An exception to this would be
contaminated equipment impeding operations due to lack of deck space, etc.
The IMDG Code and ADR allow surface contaminated objects to be transported unpackaged
under the following conditions:
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If under routine conditions of transport there will be no escape of radioactive contents or
loss of shielding - this can be achieved by fitting end caps to tubulars / drill pipe; sealing
open ends of valves, pumps, etc with flange protectors or heavy duty polythene; or
wrapping the entire item in heavy-duty polythene, as appropriate. Any externally
contaminated items must be wrapped in heavy-duty polythene.
For accessible surfaces the non-fixed contamination must not exceed 4 Bq/cm2 and the
fixed contamination 40 k Bq/cm2.
For inaccessible surfaces the non-fixed plus the fixed contamination must not exceed 40
k Bq/cm2. Measures must be taken to ensure that the radioactive material from
inaccessible surfaces is not released into the conveyance or vehicle, again this can be
achieved through the use of end caps, flange protectors, polythene wrapping, etc.
Prior to contaminated equipment / waste being shipped from the site, the RPS should contact the
AzSPU Radiation Protection SPA in order to determine the facility to be used for cleaning /
disposal; the SPA will liaise with the RPA. For offshore facilities, the Platform Materials /
Logistics Coordinator will ensure that 24 hours notification has been sent to the Supply Base
prior to shipping.
Further instructions for the storage and handling of NORM contaminated equipment and wastes
are provided in the AzSPU Procedure for Management of NORM (AzSPU-HSSE-DOC-00097-
2).
5.3
TRANSPORTATION OF NORM CONTAMINATED SAMPLES
The activity concentration of radioactive material can only be determined by analysis at a
suitable laboratory. NORM samples may be in the form of solids such as sand, sludge, scale and
wax, liquids such as produced water, and samples of gas.
Due to the nature of NORM it is not always possible to know the type or quantity of radioactive
material that is present in a sample, however, certain assumptions can be made based on past
experience.
Solid samples can be transported as Exempt (i.e. not radioactive) provided the sample weights do
not exceed those stated below:
1-4 samples - maximum weight per sample 50g.
5-8 samples - maximum weight per sample 25g.
The values above are based on a conservative assumption that the specific activity could be up to
50 Bq/g. The RPS must monitor the samples to ensure that this specific activity is not exceeded.
Provided the contamination level of the material does not exceed 30 counts per second, the above
conditions apply.
Exempt samples can be couriered to the Tracerco Laboratory in Billingham (address in Appendix
C) in the same way as any other parcel, as long as there is nothing else in the sample that would
require it to be transported in accordance with the dangerous goods legislation.
Control Tier: 2
Revision Date: 1 July, 2010
Document Number: AZSPU-HSSE-DOC-00115-2
Print Date: 2/1/2011
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