HSE Specification - Ionising Radiation€¦ · Web viewEach consignment of radioactive materials transported into Oman by air shall be accompanied by a Shipper’s IATA Dangerous

Petroleum Development Oman L.L.C.

Health Safety Environment & SD

Specification for Ionising Radiation

User Note:

The requirements of this document are mandatory. Non-compliance shall only be authorised by the Document Owner or his Delegate through STEP-OUT approval.

A controlled copy of the current version of this document is on PDO's EDMS. Before making reference to this document, it is the user's responsibility to ensure that any hard copy, or electronic copy, is current. For assistance, contact the Document Custodian or the Document Controller.

Users are encouraged to participate in the ongoing improvement of this document by providing constructive feedback.

Please familiarise yourself with theDocument Security Classification Definitions

They also apply to this Document!

UNRESTRICTED Document ID: SP-1237 May-23 Filing Key: Business Control

http://sww3.pdo.shell.om/getdoc?dataid=3966312

mailto:[email protected]?subject=Ref:%20SP-1219,%20Well%20Engineering%20H2S%20Specification

mailto:[email protected]?subject=Ref:%20SP-1219,%20Well%20Engineering%20H2S%20Specification

Petroleum Development Oman LLC Revision: 2Effective: 1 May 2011

This page was intentionally left blank

Page 2 SP-1237 : Specification for Ionising Radiation Printed 18/05/2023

The controlled version of this CMF Document resides online in Livelink®. Printed copies are UNCONTROLLED.


i Document AuthorisationAuthorised For Issue

Document Authorisation

Document Authority(CFDH)

Document Custodian Document Controller

Dr Suad Al-LamkiHead of Occupational HealthRef. Ind: MSE/3

Date: 1 May 2011

Brett YoungSenior Industrial Hygienist & Corporate Radiation Focal PointRef. Ind: MSE/32

Date: 1 May 2011

Brett YoungSenior Industrial Hygienist & Corporate Radiation Focal PointRef. Ind: MSE/32

Date: 1 May 2011




ii Revision HistoryThe following is a brief summary of the 4 most recent revisions to this document. Details of all revisions prior to these are held on file by the issuing department.

Version No. Date Author Scope / RemarksVersion 2.0 1/ 11/2010 Brett Young

Ref. Ind: MSE/32

Changes to maximum source size

Incorporates RPS into Contractors

Incorporates PtW, Radiography Certificate and Job Specific HSE plan for all radiography work

Alarming dose meters for Classified Radiation Workers

Notification of lost or abandoned sources to MECA

Version 1.0 18/02/2002 Wayne Austin

Ref. Ind: CSM/32

Date: 01/01/02

Initial issue. Supersedes:

HSE-SM: Ch 4, s 6.0 (Rev.1, Oct-96) and Ch 12, s3.5.6 (Rev.0, Oct-96);

OHMG: Section 2, GN13 (1996)

iii Related Business Processes

Code Business Process (EPBM 4.0)

iv Related Corporate Management Frame Work (CMF) DocumentsThe related CMF Documents can be retrieved from the Corporate Business Control Documentation Register TAXI.



http://sww9.pdo.shell.om/dept/tsd/tcc/tcp/apps/taxi/index_sub.htm%20


TABLE OF CONTENTS

i Document Authorisation........................................................................................................3

ii Revision History....................................................................................................................4

iii Related Business Processes.................................................................................................4

iv Related Corporate Management Frame Work (CMF) Documents........................................4

1 Introduction............................................................................................................................ 7

1.1 Purpose........................................................................................................................... 7

1.2 Scope.............................................................................................................................. 7

1.3 Definitions........................................................................................................................ 7

1.3.1 Units................................................................................................................................ 8

1.4 Basic Rules for using radioactive materials.....................................................................8

1.5 Legal and Other Requirements........................................................................................9

1.6 Deliverables..................................................................................................................... 9

1.6.1 Records..................................................................................................................... 9

1.6.2 Reports..................................................................................................................... 9

1.7 Review and Improvement................................................................................................9

2 Performance Requirements.................................................................................................10

2.1 Performance Monitoring................................................................................................10

3 Organisation & Responsibilities...........................................................................................12

3.1 Radiation Advisory Committee......................................................................................12

3.2 Corporate Radiation Focal Point....................................................................................12

3.6 Directors and Project Managers....................................................................................14

3.7 Corporate Functional Discipline Heads.........................................................................14

3.8 Contract Holders............................................................................................................14

3.9 Contractors and Sub-Contractors..................................................................................15

4 Radiation Safety Management System...............................................................................16

5 Import.................................................................................................................................. 17

5.1 Radioactive Source Shielding........................................................................................17

5.2 Radioactive Source Movement Control.........................................................................18

6 Transport............................................................................................................................. 19

6.1 General Requirements..................................................................................................19

6.2 Ministerial Decree Requirements for Transport of Radioactive Materials......................19

6.3 Additional Requirements for Transport of Radioactive Substances...............................20

7 Storage................................................................................................................................ 22

7.1 Ministerial Decree (MD 249/97) Requirements for Storage of Radioactive Materials....22

7.2 Additional Requirements for the Storage of Radioactive Sources.................................22

7.3 Radioactive Source Integrity Monitoring........................................................................23

7.4 X-ray Equipment............................................................................................................23




8 Use...................................................................................................................................... 26

8.1 General Requirements..................................................................................................26

8.2 Occupational Dose Limits..............................................................................................27

8.3 Dosimetric Control.........................................................................................................28

8.4 Work Area Classification and Entry Restriction.............................................................28

8.5 Instruments....................................................................................................................29

8.6 Training.........................................................................................................................29

8.7 Medical Control..............................................................................................................30

8.8 Design and Use of Shielded Enclosures (Fixed Facilities)............................................30

9 Disposal............................................................................................................................... 31

9.1 Abandonment of Radioactive Materials (stuck in-hole while logging)............................31

10. Emergency Response.........................................................................................................32

11. References.......................................................................................................................... 33

Appendix A Radioactive Source Consignment Note........................................................34

Appendix B – Storage Facility Design........................................................................................36

Appendix C – Radiography Supplementary Certificate...............................................................39




1 Introduction

1.1 PurposeThis Specification describes PDO's requirements for managing radioactive materials and generators of ionising radiation to protect people and the environment from harmful effects of ionising radiation.

1.2 ScopeThis Specification applies to all PDO, Contractor and Sub-Contractor activities involving ionising radiation and outlines the requirements to be fulfilled.

The Specification does not apply to non-ionising radiation such as microwave, radiofrequency, ultraviolet, visible light and infrared radiation.

This Specification does not address Naturally Occurring Radioactive Materials (NORM) which is covered in SP-1170, HSE Specification - Management of Naturally Occurring Radioactive Materials.

1.3 Definitions

Sources of ionising radiation used within PDO can be divided into:

1. Sealed sources: Chemical sources emitting gamma rays and/or neutrons (Used in well logging, fluid density, phase and thickness measurements and industrial radiography).

2. Unsealed sources: Radioactive tracers (used in production flow investigations).3. Generators: X-ray equipment such as those used in production chemical (X-ray

fluorescence XRF), industrial radiography and medical imaging and miniature particle accelerators (Minitron) emitting high energy neutrons (used in well logging).

Ionising Radiation: Radiation that produces ionisation in matter. Examples are alpha particles, beta particles, gamma-rays, X-rays and neutrons, often denoted by α, β-, γ, X- and n-radiation respectively.

Radioactive materials: are defined in Oman as any material with an activity concentration greater than 100 kBq/kg (100 Bq/g).

Classified Radiological Worker: Individuals who through the course of their work are likely to receive an annual dose equal or greater than 2 mSv/year. Personal monitoring and medical surveillance are mandatory for radiological workers.

Controlled Area: An area where immediate dose rates can exceed 7.5 µSv/h. Only Classified radiation workers shall enter into Controlled Areas.

Supervised Area: An area where the immediate dose rate exceeds 2.5 µSv/h but does not exceed 7.5 µSv/h.

Sealed Source: A radioactive substance sealed in a container which has sufficient mechanical strength to prevent contact with and dispersion of the radioactive material under the conditions of use and wear for which it was designed.




1.3.1 UnitsBecquerel (Bq) is the S.I. unit for the quantity of radioactivity defined as equal to one nuclear disintegration per second.

Curie (Ci) is the traditional unit for measurement of radioactivity based on the activity of one gram of radium, i.e. 37 billion disintegrations per second.

1 Becquerel, Bq = 27 pCi (27 x 10-12 Ci)

1 Curie, Ci = 37 GBq (37 x 109 Bq)

The Gray is the SI unit of absorbed radiation dose due to ionizing radiation. The gray measures the deposited energy of radiation. The biological effects vary by the type and energy of the radiation and the organism and tissues involved. The equivalent dose to a tissue is found by multiplying the absorbed dose, in gray, by a dimensionless “quality factor" Q. (SI unit Sievert). The dose in Sievert = Dose in gray x Wr. The radiation Weighting factors for alpha particles is 20, for neutrons approximately 10 and for gamma rays, X-rays and beta particles 1.

Table 1: Units

Quantity Units Relationship

Old New

Radioactivity Curie Ci Bequeral Bq 1 Ci = 37 x 109 Bq

Dose Rad Gy 100 Rad = 1 Gy

Equivalent Dose Rem Sv 100 Rem = 1 Sv

1 Rem = 10 mSv

1 milliRem = 10 uSv

Controlled Area mRem/h uSv/h 0.75mRem/h = 7.5 uSv/h

Supervised Area mRem/h uSv/h 0.25mRem/h = 2.5 uSv/h

1.4 Basic Rules for using radioactive materialsAn increase in a person’s exposure to ionizing radiation, even at low doses, is assumed to increase the risk of harm to that person’s health. PDO, Contractors and Sub-Contractors shall justify the use of radioactive materials. No practice of using radioactive materials shall be authorised unless the practice produces a positive net benefit (Justification of a proactive or cost-benefit principle)

Every radiation employer, in relation to any work with ionising radiation, must take all necessary steps to restrict exposures to As Low As Reasonably Practicable, economic and social factors being taken into account (Optimisation of protection or ALARP principle).

The decision to use radioactive sources or generators over non radioactive sources or techniques requires a written risk assessment to demonstrate the justification and that the risks to HSE are ALARP. This applies to fixing radioactive sources in PDO locations, running radioactive sources, tracers and pip tags down-hole and using radiography over techniques such as Auto Ultrasonic and Ultrasonic Time of Flight Diffraction.

The effective dose to individuals shall not exceed the limits recommended. (Dose and risk limitation principle). Controls for protecting persons against exposure to radiation shall be aimed at utilising the smallest source suitable to undertake the job, minimising the time of exposure, maximising the distance and shielding from the radiation source, utilising competent, trained personnel and ensuring no one can ingest or inhale radioactive materials.




1.5 Legal and Other RequirementsLegal requirements for the import, transport, storage or use of radioactive materials in the Sultanate of Oman are established in Ministerial Decree - MD 249/97 "Regulations for the Control and Management of Radioactive Materials". This Ministerial Decree is administered by the Ministry for Environment and Climate Affairs (MECA).

Oman is a Member of the International Atomic Energy Agency (IAEA). The IAEA has developed a comprehensive list of safety standards of which Oman has incorporated the Regulations for the Safe Transport of Radioactive Materials into MD249/97.

The Ministry of Manpower Occupational Health and Safety Regulations in the Private Sector also includes a section on ionising radiation and dose limits which have been incorporated into this Specification.

Any Organisation dealing with radioactive materials shall establish an internal radiation management system including staff structure with well defined responsibilities, written procedures of work, quality assurance procedures, staff training and emergency procedures so as to meet the Ministry’s and PDO’s requirements.

In addition, PDO will adhere to recommendations of the International Commission on Radiological Protection provided these recommendations meet or exceed the requirements of MD 249/97.

1.6 Deliverables

1.6.1 Records

Records shall be maintained to document the implementation of this Specification and shall be outlined in the Contractors / Sub-Contractors Radiation Safety Management System and safe working procedures. Records shall include a register of radiological workers, personal radiation dose rates, site audits and inspection reports, registration of radioactive materials and radiation generators, wipe testing, transportation, storage and inspection measurements and disposal or return to manufacturer.

1.6.2 Reports

Any non-compliance with this Specification shall be notified to the PDO Project Manager, Contract Holder or Principal Contractor in relation to Sub-Contractors. Pending the severity of the non-compliance an investigation shall be undertaken and the findings reported as above. Further information on reporting non-conformances is outlined in CP-122 “HSE Management System Manual”.

1.7 Review and ImprovementAny user of this document who encounters a mistake or confusing entry is requested to immediately notify the Document Custodian using the form provided in CP-122 “HSE Management System Manual”.

This document shall be reviewed as necessary by the Document Custodian, but no less frequently than every four years. Triggers for full or partial review of this Specification are listed in CP-122 “HSE Management System Manual”.




2 Performance Requirements

2.1 Performance MonitoringThe responsibility for the importation, transport, storage, emergency response and use of radioactive materials rests with the owner (custodian) referenced on the MECA permit and shall be subjected to performance monitoring in accordance with the owners radiation safety management system and Contractual requirements.

Contractors and sub-contractors who own and utilise radioactive materials and generators shall be pre-approved by the Corporate Radiation Focal Point & CFDH prior to acceptance onto the PDO vendor list. This will include a pre-approval audit and review of the Contractors/ Sub-Contractors Radiation Safety Management System and safe working procedures.

2.1.1 Project Managers and Contract Holders

Project Managers and Contract Holders shall undertake regular audits of contractors handling, storing or transporting radioactive materials and generators for PDO activities. The audit program shall include a review of the owners Radiation Safety Management System and Procedures to demonstrate compliance with this Specification. After the initial start-up audit, the period of inspections and audits conducted by the Project Manager or Contract Holder shall be as a minimum six monthly and shall involve personnel with radiation expertise (i.e. Radiation Protection Supervisor for that type of radioactive material and usage). The audit findings shall be provided by the Contract Holder to the Corporate Radiation Focal Point (CRFP) who will present the findings to the PDO Radiation Advisory Committee (RAC).

2.1.2 Contractors

Contractors importing, handling, storing and transporting radioactive materials and generators within the PDO Concession Area shall undertake their own internal audits and inspections as part of their own quality assurance program and shall involve personnel with radiation expertise. In addition, as regular inspection program shall be developed and conducted by site personnel on a more frequent basis. This shall be lead by the site radiation protection supervisor. The results of the audits and inspections shall be made available directly to the Contract Holder, CFDH or Principal Contractor during third party audits. As a minimum the source owner shall conduct audits every six months of each location where sources are handled and stored.

2.1.3 Sub-Contractors

Sub-contractors importing, handling, storing and transporting radioactive materials and generators shall be subject to an audit and inspection program established by the Main Contractor to PDO. After the initial start-up audit, as a minimum the audits shall be conducted six monthly at each interior location(s) and shall involve personnel with radiation expertise (i.e. Radiation Protection Supervisor for that type of radioactive material and usage). The sub-contractor shall establish a regular inspection program conducted by site personnel on a more frequent basis. This shall be lead by the site radiation protection supervisor. The Main Contractor to PDO shall provide the inspection and audit findings to the relevant PDO personnel such as the EMC/ODC Contract Holder or Company Site Representative, PDO CFDH or to the PDO Project Manager for review not less than six monthly. The Contract Holders and/or Project Managers shall refer the audit reports to the CRFP for peer review who will present the findings to the RAC.

The CRFP will conduct periodic audit programs of contractors and sub-contractors and review findings with contract holders and project managers. The CRFP can be requested to partake in audits and inspections. Refer Table 2: Performance Monitoring which outlines roles, responsibilities and accountabilities with respect to implementation and operation.



Table 2: Performance Monitoring - RASCI Chart

Responsible Accountable Support Consult Inform

R A S C I

Monitoring Activity Project Managers

Contract Holders

Company Site Representatives

Contractors Sub-Contractors CFDH CRFP Asset / Project HSE Team

Pre-approval of Contractors and Sub-Contractors using radioactive sources & generators

S S R & A R & A S

Radiation Safety Audits of Contractors using radioactive sources & generators

R & A R & A S S & I S & I S

Radiation Safety Audits of Sub-Contractors using radioactive sources & generators

I R & A I I C

Develop audit schedule and perform internal audits as per radiation safety manual

I R & A R & A

Provide audit findings and learning’s to CFDH & CRFP for lateral learnings

R R I I S

Review monthly TLD Dose reports I I R R I

Compile findings to RAC S R & A

3 Organisation & Responsibilities

3.1 Radiation Advisory CommitteeThe Radiation Advisory Committee (RAC) defines and approves PDO’s policy and/or specifications and procedures with respect to operational and administrative management of radiation protection. The RAC is advised by the Radiation Protection Advisor (RPA – an external consultant) who will be the source of expertise for all matters concerning protection against the hazards of ionising radiation.

The RAC will ensure, through development of appropriate policies, specifications, and/or procedures,

The application of radiation protection principles laid down in the IAEA Basic Safety Standards for protection against ionising radiation and for the safety of radiation sources 1996

The protection of its personnel, contractors, members of the public and the environment against the hazards of exposure to ionising radiation due to PDO work activities.

The avoidance of loss of sources and uncontrolled release of substances contaminated radioactive materials.

The minimisation of radiological effects of PDO work activities carried out in the past. The avoidance of the need for classified PDO radiation workers, wherever reasonably

practicable.

The RAC reports to PDO’s Managing Directors Committee (MDC) and is comprised of:

Chairman OSD

Corporate Radiation Focal Point (acts as the RAC secretary) MSE/3 Rep.

Environmental Advisor MSE/2 Rep.

Asset Managers (as needed) OSO/ONO

Well Engineering Representative (as needed) UWZ Rep.

3.2 Corporate Radiation Focal PointThe CRFP will be the first source of expertise within PDO for matters concerning the protection against the hazards of ionising radiation and shall hold a Radiation Protection Supervisor certificate. When lacking knowledge or information the CFRP may call in the help/advice of the RPA. Further, the CRFP:

Is secretary to the RAC. Communicates with competent authority on PDO matters concerning the protection

against the hazards of ionising radiation. Monitors the PDO radiation protection policy implementation. Is current on all potential ionising radiation issues within PDO. Is responsible and accountable for pre-approving contractors utilising radiation sources

and generators Is the contract holder and interface to the external RPA.

3.3 Interior Radiation Protection Supervisors (RPS)Any contractor or sub-contractor utilising radioactive materials in the PDO Concession area shall appoint a competent Radiation Protection Supervisor (RPS) for each location. The RPS will be the first source of working knowledge within the interior for matters concerning the protection against the hazards of ionising radiation. The RPS shall be experienced in monitoring routine and non-routine situations involving the type of ionising radiation they are


handling. The RPS shall be appointed by the Radiation Protection Advisor and endorsed by the company management, and agreed by the operator, that he understands his role.

In case of lacking knowledge/expertise or doubt RPS may directly call in the help/advice to the contractors Senior Radiation Protection Supervisor or appointed Radiation Protection Advisor.

The RPS shall be competent and fully conversant with:

Supervising work involving ionising radiation. Setting up Controlled or Supervised Areas. Monitoring and sampling. Quality assurance of radiation protection. Ensuring compliance with procedures and regulations (e.g. packaging, transport,

disposal). Emergency provisions in the event of an incident Reporting and investigating incidents Record keeping requirements

3.4 Senior Radiation Protection Supervisors (Coastal)Any contractor or sub-contractor utilising radioactive materials in the PDO Concession area shall appoint a competent Senior Radiation Protection Supervisor (SRPS) who shall be the first source of radiation expertise within the Contractor and/or Sub-Contractor. The Senior RPS is responsible for:

Monitoring compliance with this Specification for the storage, transport and use of radioactive sources at all worksites.

Formulation and review of work procedures and contingency plans, where necessary, to ensure safe working practices and adequate emergency response.

Implementing a comprehensive system of movement control of all sources of ionising radiation imported into Oman, such that their location is known at all times.

Organising comprehensive medical screening (as defined in this Specification) of all workers exposed to ionising radiation, and maintenance of adequate medical records.

Training and monitoring of all workers exposed to ionising radiation, to ensure that they perform their assigned work without endangering themselves, fellow workers, members of the public and the environment.

Implementing adequate dosimetry control, as defined in this Specification, for the work being performed, and the maintenance of adequate records.

Rigorously reviewing dosimetry records; Investigating and reporting all incidents involving over-exposure to ionising radiation as

defined in Section 8.3 and the Contractors own radiation safety manual. Investigating and reporting all incidents involving the loss (even temporary) of a source

of ionising radiation.

When lacking knowledge or information, the SRPS shall call upon the Company appointed Radiation Protection Advisor (RPA) for advice and assistance.

3.5 Radiation Protection Advisers (RPA) and/or Health PhysicistsAll Contractors or Sub-Contractors utilising radioactive materials in the performance of their work for PDO shall appoint (on staff, or under contract) one suitably qualified Radiation Protection Adviser (RPA) or qualified Health Physicist to advise on matters relevant to radiation safety for their operations in Oman. The responsibility for compliance with this Specification is not delegated to the RPA and remains the responsibility of the operating organisation.




The RPA provides specialist advice and technical assistance to the organisation and shall be trained in radiation hygiene and radiation safety management. Appointed RPA’s shall be familiar with Oman’s radiation legislation and publications from International Regulatory Bodies such as the IAEA and the ICRP. The RPA is responsible for:

Advising management on the implementation of the company’s radiation safety management system.

Monitoring compliance with this Specification for the storage, transport and use of radioactive sources at all worksites through planned inspections and audit programs.

Formulation of safe working procedures (local rules) and contingency plans, where necessary, to ensure safe working practices and adequate emergency response.

Training and monitoring of all workers exposed to ionising radiation, to ensure that they perform their assigned work without endangering themselves, fellow workers and the environment

Peer reviewing investigations of incidents involving over-exposure to ionising radiation and incidents involving the loss (even temporary) of a source of ionising radiation.

The Contractor shall ensure that the RPA or equivalent holds sufficient competency and formal training in all aspects of the work to meet the requirements of an RPA.

All RPA’s and/or Health Physicists shall be formally trained in all aspects of the work and be certified under the RPA2000 assessment scheme (United Kingdom), or equivalent. If the nominated RPA does not fulfil the above certification requirements, the Contractor shall submit a current resume for approval by the Corporate Radiation Focal Point.

The RPA shall be available at all times through a call-out system, but the permanent presence of the RPA at the worksite is not required.

3.6 Directors and Project Managers Directors and Project Managers are responsible for ensuring that the activities they control are managed in accordance with the requirements of this Specification. In the event that circumstances prevent compliance with this Specification, they shall seek step-out approval through the Document Custodian (refer to CP 122 HSE Management System Manual, Part 2 Chapter 3).

3.7 Corporate Functional Discipline Heads Corporate Functional Discipline Heads are responsible for ensuring that the requirements of this Specification are reflected in the documents for which they are responsible. Any CFDH responsible for pre-approval of contractors or sub-contractors using ionising sources shall undertake a pre-approval audit of the HSE and radiation safety management system of the contractor. The audit team shall contain personnel with radiation expertise to verify compliance against the Law of the Land, this Specification and the contractors own safety management system.

3.8 Contract Holders Contract Holders are responsible for communicating this Specification to Contractors, and for ensuring that the requirements of this Specification are adhered to within the scope of their contracts. Contract Holders shall appoint a Company Site Representative (CSR) who shall be instructed and trained as required to monitor (inspect and audit) the activities of personnel involved in working with radioactive materials. Contract Holders shall ensure that all radioactive materials have been removed and safely disposed upon the completion of the contract. In the event that circumstances prevent compliance with this Specification, Contract Holders shall seek step-out approval (refer to CP 122 HSE Management System Manual).




3.3 Contractors and Sub-ContractorsContractors and Sub-Contractors are responsible for ensuring that activities undertaken within the scope of their contracts are managed in accordance with the requirements of this Specification and the Ministerial Decrees. This may include any or all of the following:

developing a radiation safety management system and safe working procedures to keep exposures to ionising radiation to ALARP;

obtaining all necessary permits and authorizations;

construction of shielded enclosures at permanent facilities/workshops for minimising radiation exposures, allowing controlled radiography through day operations

appointing competent Radiation Protection Advisor and site based RPS’s;

providing consultation and appropriate training for employees who may be exposed to radiation in their work;

ensuring that a plan for the control of exposure to radiation is developed, in consultation with the exposed workforce, and that it is followed;

developing and implementing a plan for monitoring exposure to radiation and for estimating doses received by those exposed;

ensuring that doses estimated to have been received by employees comply with the relevant dose limits and are consistent with any applicable dose constraints;

ensuring that doses estimated to have been received by members of the public from the operation comply with the public dose limits or any applicable public dose constraints;

developing a plan for dealing with incidents, accidents and emergencies involving exposure to radiation;

keeping records relating to radiation exposure resulting from the operation; and providing copies of dose records to employees on request and at the termination of their employment.

Disposing of radioactive materials in accordance with the Ministerial Permit and IAEA requirements and maintaining records to document safe disposal.

3.10 Radiological WorkersEmployees are responsible for observing radiation safety practices, as set out in the Radiation Safety Manual and comply with the relevant safe work procedures. Employees shall be consulted and participate in the development of safe working procedures and Job HSE Plans for controlling radiation in the workplace.

A prospective employee should assist the prospective employer by providing the employee’s previous occupational radiation dose history. Where an employee suspects he has received a dose above the limits (Section 8.3) he shall notify the Site in Charge (SIC) or Radiation Protection Supervisor (RPS) immediately. Employees shall report all defective or faulty equipment and shall report non-conformances to the SIC or RPS. Under no circumstances shall a radiological worker perform their work without wearing a TLD or Film badge. Personnel found working without their TLD badge shall be excluded from all work involving ionising sources until the TLD or an authorized replacement is provided.




4 Radiation Safety Management SystemOwners of radioactive sources for use for PDO activities shall develop a comprehensive radiation safety management system that incorporates quality assurance and outlines:

The Organisational chart and allocated responsibilities Importation of radioactive materials or generators Transportation Storage (within Muscat and interior locations) Training Operations and maintenance activities (including Job HSE Plans to be attached to the PtW) Dosimetry and Instrumentation Disposal Emergency Response.

In addition, the owner shall have documentation referred to as “Accompanying Documents” which shall be provided with the apparatus intended for the users. The documentation is divided into five categories:

1. Description and technical characteristics of the apparatus and sources including;

suitable photos or drawings to allow identification of the main elements and parts of the apparatus

explanation of the operation, with reference to diagrams, indicating the sequence by which the source assembly is partially or completely outside of the exposure container or exposure head.

Specification of characteristics of sealed sources that can be used in the exposure container

Retention device of the source holder2. Certificates of the manufacturer to show compliance with the International standard e.g.

ISO2919

3. Instructions for use including;

instructions for assembling the various parts of the apparatus in its various configurations

instructions on the storage of the container

instructions on the use of protective caps, plugs or similar devices on the apparatus while not in use, so as to avoid accidental penetration by foreign bodies

4. Inspection, maintenance and repair procedures including;

instructions on replacing the loaded source assembly and the packaging of the decayed sources for transport and disposal

instructions on the procedure and frequency of maintenance operations instructions for checking the apparatus for internal cleanliness, deformation, breakage or

wear Instructions to be followed in the event of foreseeable accidents, with an indication of their

probable causes.5. Instructions for disposal including;

when the sealed source and exposure containers have reached the end of their working life, they shall be disposed of in a safe and proper way in accordance with the permit and regulations for the control of radioactive materials, in particular for packaging and transportation.




5 ImportThe appropriate shipping certificate and permit as per the requirements of MD 249/97 shall accompany all imports of radioactive materials.

Records of the import of radioactive materials shall be kept. Such records shall include:

Owner (Custodian) Name Sealed or unsealed Radioactive nuclide (substance) and activity (Bq) Type of radiation & half-life Transport Index in designated transport shield Purpose of source Date of receipt Storage location

Similarly, the records of the importation of X-ray or Neutron generators shall be kept, including the following information:

Custodian company. Equipment reference code or type identification. Type of energy emitted (X-ray or Neutron). Maximum beam voltage (X-ray equipment). Purpose of generator. Date of receipt. Storage location.

Where Ir 192 is used as a gamma source for NDT, it shall not exceed a strength of 1.11TBq (30 Curies) on site without written approval from the PDO Corporate Radiation Focal Point. The Contract Holder or Project Manager shall submit a risk assessment including additional controls in the event of a step out request to utilise larger sources (> 30 Ci) for heavy wall piping or justify why alternate NDT techniques such as Auto Ultrasonics cannot be utilised.

5.1 Radioactive Source ShieldingMD 249/97 requires that:

Packaging of all radioactive materials shall be in accordance with International Atomic Energy Agency (IAEA) regulations regarding transport, and any requirements of the MECA. Where the supplier provides packaging, the organisation shall obtain copies of approval certificates and submit them to the MECA. In cases where the supplier does not pack the material, MECA approval shall be obtained before use.

The international classification and radiation dose limitation on Type A and Type B packages shall conform to a maximum dose rate of 2 mSv/h at the surface and transport index 10 for each package.

Packages of radioactive materials shall be labelled as per IAEA regulations.

Accordingly:

Selection of sealed radioactive sources shall be as per ISO 2919. All radioactive sources shall be contained in shields which:

- reduce the maximum radiation level to 2 mSv/h at the shield surface and 0.1 mSv/h at 1 meter from the surface.

- maintain their shielding properties at 800°C - have adequate security locks preventing access to the source by unauthorised

persons.- carry permanent labelling with the following information:




- type of radioactive material (nuclide).- activity (in Bq).- the word "RADIOACTIVE" in clear and indelible print, in English and Arabic.- the Trefoil radiation sign in black on a yellow background.- the custodian's name and contact telephone in Oman.- Class 7 Diamond, UN Number and Transport Index - Projectors shall have the source plate properly fixed to the container. (Wire

attachment handle is not acceptable) All sources and their shields shall be certified by an IAEA Certificate of Competent

Authority, issued by the regulatory agency in its country of origin.

5.2 Radioactive Source Movement ControlSource owners shall track and maintain reports of source movements within the PDO Concession area and shall at any time be able to advise the Contract Holder, CRFP or Ministry officials of the source location.

A Radioactive Source Consignment Note shall be completed for each movement of radioactive materials from Muscat to interior locations and return of sources moved from one interior storage location to another for use will also require completion of the Source Consignment Note e.g. Fahud to Yibal. (Refer Appendix A).

Sources used within the Asset they are registered for use do not need daily completion of the Source Consignment Note, however a logging system containing the above information must be implemented to verify source movement and usage by the Radiation Store Manager or Site in Charge and approved users.

The following information shall be maintained:

Contract Number working under

Contractor/Sub-Contractor details

MECA Permit Number

Approved storage location

Date of arrival on PDO site

Source serial number

Radionuclide(s)

Size of source on-site (Ci & Bq)

Date of last wipe test and next due

Site RPS Name and Contact number

The Site Radiation Protection Supervisor of each storage facility shall maintain a log for each source stored containing the following information:

Type and serial number of the source. Date and time out of store. Destination of source. Signature of person removing source. Date and time of return. Signature of person returning source.




6 Transport

6.1 General RequirementsPDO’s HSE Specification – Road Transport SP2000 describes PDO's minimum requirements for managing road transport safety. It describes the minimum requirements for driver qualifications, vehicle standards, and Journey management including the route of delivery. It is the consignor’s responsibility to comply with the transportation rules.

The following shall apply specifically to the transport of radioactive materials.

6.2 Ministerial Decree Requirements for Transport of Radioactive Materials

MD 249/97 requires:

Transportation of radioactive materials into or out of the Sultanate of Oman shall be carried out in accordance with the IAEA Regulations for the Safe Transport of Radioactive Materials TS-R-1 (2009).

Transportation of radioactive materials within the Sultanate of Oman is only allowed by land. Transport by post or internal flights are not allowed.

Vehicles used for the transport of radioactive materials within the Sultanate of Oman must obtain approval of the Directorate General of Civil Defence (ROP) before being used.

The limitations for the transport of radioactive materials shall be as follows:- the maximum dose at any point on the outer surface of any vehicle loaded with

radioactive materials shall be 2 mSv/h- the maximum dose rate at one metre distance from the outer surface of any vehicle

carrying radioactive materials shall be 0.1 mSv/h- the maximum dose rate at the driver’s seat shall be 2.5 Sv/h unless he is

classified, taking into account the time for the trip.- any radioactive packages must be placed in tightly sealed containers, securely fixed

to the vehicle’s floor and padlocked. The container must be placed in a manner that minimises the dose rate at the driver’s seat and should not be close to the rear of the vehicle.

- no radioactive material shall be kept in the driver’s compartment of the vehicle.- nobody is allowed to travel with any radioactive consignment other than the driver

and those authorised to do so.- agricultural products, livestock, flammable materials or explosives shall not be

transported as part of a radioactive materials consignment. Vehicles carrying radioactive materials shall be labelled on both sides and the rear

indicating that radioactive materials are being carried. The labels shall be in Arabic and English. The labels shall be removed when the vehicle is not carrying radioactive materials.

Each consignment of radioactive materials transported into Oman by air shall be accompanied by a Shipper’s IATA Dangerous Goods certificate.

Any movement of radioactive materials from Muscat to the PDO concession area by road shall be recorded using a Radioactive Source Consignment Note (See Appendix A) or a similarly PDO approved transport certificate and include a Tremcard.

Radioactive materials shall be transported with minimum stops en route to the destination. The vehicle shall stop only at places specified in the permission. Each driver of a vehicle carrying radioactive materials shall not drive for more than 4 hours without a break and shall not work for more than 10 hours in a day.




6.3 Additional Requirements for Transport of Radioactive SubstancesIn addition, the following requirements shall apply to the transport of radioactive substances:

Suitably trained radiological workers shall supervise any transport of radioactive material. Transport shields for radioactive sources shall comply with Section 5.1. Upon arrival, radioactive material shall remain in its transport container and the RPS or

management notified. Only after receipt of a signed and completed consignment note shall the radioactive material be transferred to the approved radiation store specified on the consignment note.

For transportation by road the vehicle shall comply with SP 2000 Road Transport and the following:

- have a dedicated fire resistant compartment for the transport of radioactive materials.

- be fitted with:- warning notices front and rear indicating the type of radioactive material

carried, its activity in Bq, the name and contact telephone of the owner. These notices shall be removable and only displayed when the vehicle is actually transporting radioactive material.

- yellow and black Trefoil warning signs on all sides of the source container, and a written warning in English and Arabic.

- two portable fire extinguishers of dry chemical powder type, two portable orange coloured flashlights and fireproof warning signs front and rear.

- a tool kit for emergency repairs to the vehicle and one spare tyre or two spare tyres if driving on graded roads.

When transported by road the transport shield shall be contained within the dedicated compartment fixed to the structure of the vehicle. The compartment door shall be locked. Additionally, the transport shield shall be physically secured to the compartment by a latching mechanism, padlock or chain. No other Dangerous Goods, other than Class 7 radioactive materials, shall be transported in the source storage compartment. Personnel shall not be transported in the compartment.

All vehicles transporting radioactive materials shall be occupied by at least two people, at least one of whom shall be a trained radiological worker. The dose rate in the driver or passenger compartment shall not exceed 2.5 Sv/h. Only radiological workers shall be permitted to enter into areas on the vehicle exceeding 7.5 Sv/h. No persons, other then those designated at dispatch of the vehicle, may be transported.

Vehicles containing radioactive sources should never be left unattended outside of designated workplaces where the source is to be utilised. When stationary, vehicles containing radioactive sources shall be separated from other vehicles by a minimum distance of 2 metres.

All drivers shall undergo, as a minimum, radiation awareness training for the likely emergency scenarios that may occur en route. These include road traffic accidents, fire in the vehicle and they shall be familiar with the Tremcard, Company Emergency contact numbers and the doses likely received whilst transporting the sources.

A calibrated dose meter capable of measuring accurately to less than 2.5 Sv/h shall be carried with the vehicle when transporting sources.

All NDT projectors shall be transported in a specially designed box that protect from vibration and impact and general wear and tear during transport and loading/unloading into the stores.

Labelling

All packages containing radioactive materials must be labelled with one of the three types of labels described and illustrated below. A minimum of two labels are required for a package. They should be attached on opposite sides of the package for better indication. The term Transport Index (TI) of a package is used to express the external radiation hazard arising from a package and is determined by measuring the dose rate at 1 metre from the package (in uSv/h) and dividing by 10.




Category I White: A diamond in black and white with one red strip. It shall be used when the dose rate dose not exceed 5 uSv/h at the surface or the TI is 0.

Category II Yellow: A diamond in black, white and yellow with two red strips. It shall be used when the dose rate dose not exceed 500 uSv/h at the surface or the TI is 0-1

Category III: A diamond in black, white and yellow with three red strips. It shall be used when the dose rate dose not exceed 2 mSv/h at the surface or the TI is >1 - 10. If the TI is greater than 10, then the package is shipped under ‘exclusive use’ and the RPA must be consulted immediately.

Category I Category II Category III Type A packages are designed to prevent loss or dispersal of radioactive contents and to retain shielding under normal conditions of transport which includes minor mishaps e.g. falling from the back of a vehicle.

Type B packages must in general meet Type A requirements and in addition, be designed to withstand every accident conditions including fire. The Type of package shall be clearly marked on the outside package and any Type B package must be of a design approved by a competent authority in the country of origin. A copy of the certificate of approval must accompany the package.

Placarding of Vehicles for Transportation (in English and Arabic)

A fireproof notice to warn fire services, ROP, and others in the event of a accident shall be displayed in English and Arabic including the Type of source being carried and telephone numbers of the Contractor RPS for emergency contact.




7 Storage

7.1 Ministerial Decree (MD 249/97) Requirements for Storage of Radioactive MaterialsPermanent storage of radioactive materials shall only be permitted at places approved by the Directorate General of Civil Defence (Royal Oman Police), MECA and the Corporate Radiation Focal Point. MECA approval must be obtained for any proposed temporary locations for storing radioactive material for longer than 24 hours such as PDO EPC Projects.

Storage locations shall comply with the following:

Be away from populated areas. Be fenced within the yard of the main contractor All radioactive materials shall be adequately shielded, labelled and kept locked and

secure. The design of the facility shall be waterproof and comply with the MECA drawings in

Appendix B. Contractors and sub-contractors shall not be permitted to store their radioactive sources

within the store or pit of another contractor / sub-contractor unless the pits are separated by a block wall and have separate access.

Radioactive materials used for well logging must remain in their shield in an exclusive store or “dog kennel” and shall be located in a designated area in clear view of the driller or logging engineer until being loaded. The container shall be locked, labelled and cordoned with barrier tape. Additional precautions such as securing to a pipe wracking should be considered. Preferably the sources will be stored in a dedicated sea container whilst on-site. Permanent stores shall comply with Section 7.2.

7.2 Additional Requirements for the Storage of Radioactive SourcesPermanent storage of radioactive sources shall comply with the following:

When not being used, radioactive materials shall be kept in approved designed stores, surrounded by a security fence (ref. Appendix B), with the following characteristics:

- Re-enforced block or concrete walls and roof,- Protection of the contents from the effects of the weather.- Resistance to fire sufficient to minimise the loss of shielding, taking into account the

combustibility of the surroundings and the likely temperatures reached in the event of a fire.

- Ventilation to prevent accumulation of gases or vapours.- Storage facility and security fence individually secured by a lock. The storage

facility lock shall be operable from the inside. Storage facility and security fence shall be locked if no one is present.

- warning signs, including the Trefoil radioactive warning and the words "DANGER - RADIOACTIVE MATERIAL" written in clear and indelible English and Arabic print, exhibited on all sides of the security fence and the secured facility.

- Emergency contact details of the source owner and nominated person (RPS / SIC) - the level of radiation at the exterior of the store shall not exceed 2.5 Sv when fully

loaded with all assigned radioactive sources. - at the perimeter of the security fence the radiation level shall not exceed 1 Sv.

Note: If the store is a building within a secured area then a separate security fence is not required.

Every radioactive source storage facility shall have a nominated supervisor. This person shall be a radiological worker and shall be responsible for managing the storage




facility, including access control, and for tracking the movements of sources into and out of the store. The storage facility supervisor shall also be responsible for keeping a log of all sources normally stored at the facility, including the source type and serial number.

Radioactive source storage facilities shall be dedicated to the designated purpose, and shall contain only the sources, their shields, and any handling tools and ancillary equipment, utilised in the movement or maintenance of the sources. Furniture shall be limited to a bare minimum. At no time shall any flammables, combustibles, explosives or other hazardous materials be kept in, or in proximity to, the radioactive store. Suitable calibrated dose meters shall always be available.

The location of all such storage facilities for radioactive material within, or adjacent to, PDO facilities and/or utilised under contract to PDO shall be approved by PDO prior to construction. Such facilities shall be located away from accommodation buildings, roadways, pipelines, and storage facilities for explosives, flammables or other hazardous or toxic materials.

Radiation levels at the perimeter fence shall be measured and recorded with the maximum holding of sources present.

Only radiological workers shall be provided with access to keys to the various radiation source storage locks. Sources shall be introduced to, or removed from, storage by radiological workers only.

7.3 Radioactive Source Integrity MonitoringA competent person shall test all radioactive sources that emit alpha radiation for leakage (wipe test) every 6 months, in accordance with BS 5288 and for gamma and neutron sources in accordance with the contractors approved Radiation Safety Manual. Well logging sources shall be wipe tested every six months owing to the conditions of use. Industrial radiography equipment shall be as a minimum wipe tested every two years.

Wipes shall be sent to an accredited laboratory for evaluation. Any source found to be leaking radioactive material (where the wipe exhibits a radioactivity of 185 Bq or more) shall immediately be removed from service and disposed of in accordance with SP-1009, "Waste Management". Such incidents shall be reported to the Contract Holder and CRFP as per the requirements of HSE/97/01 “Incident Notification, Investigation, Reporting and Follow-Up".

Records of all wipe tests shall be maintained for at least 3 years and include:

The date and results of the leak testing conducted A description of the method used and laboratory details Next inspection due date

7.4 X-ray Equipment7.4.1 Crawlers and Externally Fitted X-ray Equipment

The register of X-Ray equipment must contain the:

Mark and type of equipment Maximum tube voltage of the equipment Location where the equipment is in use Dates and results of inspection measurements of X-ray equipment.

X-ray equipment shall not be left unattended in a condition where it may be operated and shall be provided with a lock on the main circuit. If the equipment is left on site for a short period, the electricity supply should be disconnected and the equipment left locked. For a longer period, the equipment should be transported to the dedicated lockable storage room to prevent unauthorised use and shall not be stored with other radiography equipment. Only authorised radiological workers shall keep keys.




The radiation safety manual shall contain the drawings and maintenance procedures for X-ray equipment for both crawlers and external X-ray equipment as used by the contractor. Where radiography is not conducted in a shielded enclosure, cable lengths shall be no less than 20 m for x-ray generators up to 300 kV and longer for equipment with higher tube potentials. All metallic items including casings, interconnecting cables, power supply unit (transformer/generator), X-ray control equipment, tube assembly, warning signals, other safety devices and the irradiated object are bonded together and grounded (connected to earth). Advice on electrical matters, as well as inspection and testing, should be provided by a qualified expert.

The Control Panel shall be fitted with the following:

A label indicating that hazardous X-rays are emitted when operating and a warning prohibiting unauthorised use including the international trefoil.

A key to switch to prevent unauthorised use which is only removable when the switch is in the off or standby position

Separate labelled warning lights to indicate when the machine is energised and X-rays generated

A timer that controls the exposure duration, or an ON/OFF switch that requires continuous pressure by the radiographer to maintain X-ray production

Indicators that show the X-ray tube potential in kV and the current in mA when the beam is ON.

The dose rate generated by using accelerators increases the potential for overexposures of radiographers. Higher radiation protection is required on site including appropriate survey meters that response accurately to the pulsed nature of the radiation field. Portable survey meters used for conventional gamma and X-ray radiography may not be suitable for use with accelerators.

Pipeline crawlers may carry either an X-ray tube or gamma source powered by batteries on the carriage or trailing cables from the generator. Initiators (control isotopes of Cs-137) shall be collimated and be stored in approved radiation stores when not in use. Initiators can give appreciable doses due to scattering from the pipe. They shall shielded when not in use and have an ISO2919 certificate.

With pipeline crawlers the useful beam width shall be restricted so that it is no greater than necessary for the radiograph (< 120 mm). It is also essential that suitable warning signals are given. The warning signals must operate automatically because unintended movement of the control source may inadvertently initiate an unplanned exposure. Warning signs must be capable of alerting people in the vicinity of the crawler under the prevailing environmental conditions. Klaxons and sirens can be used provided they can be heard in a noisy environment. Visual signals to supplement able signals in noisy environments shall also be included.

In large pipes it may be necessary for the radiographer to enter the pipe to retrieve the crawler. An atmospheric test using a multigas detector shall be conducted as per the PtW requirements for entrance into a confined space.

The radiographic source (if any) and the control source are to be housed in shielded containers and, together with the ‘tell-tale’ source, should not produce dose rates in excess of 100 uSv/hr on the accessible surface of the pipeline, except during exposure. A supervised or controlled area shall be set up around the pipe.

7.4.2 X-Ray Equipment for Medical Imaging




X-Ray equipment used for medical imaging within PDO and Contractor PAC’s shall be maintained and inspected annually by an appointed contractor. MCN shall be responsible for co-ordination of annual maintenance and inspection by a competent third party assessor within the PDO clinics. The PAC clinics which contain X-ray units shall establish a method to annually inspect and maintain their X-ray units by a competent third party assessor. The results shall be provided to MCN for review and reporting to the CRFP. MCN may at any time request to audit and inspect the PAC clinics for radiological compliance.

7.4.3 Fixed Gauges or ProfilersRadiation source owners and applicants for fixed gauges or profilers to be installed in PDO facilities shall ensure the following:

1. All work is conducted safely, in adherence to the conditions of the license, and with resultant exposures to personnel to as low as reasonably practicable (ALARP)

2. Act as liaison agent with regulatory authorities and be available for assistance in inspection and audits

3. All applicable regulations and regulatory guides, and assure that license applications are properly filled out and are submitted on time.

4. Perform, or cause to be performed (e.g., by manufacturer, consultant, or qualified employee), appropriate surveys, using operable and, calibrated instruments.

5. Perform leak tests on time.

6.Establish and maintain record systems for leak tests, shutter tests, surveys, receipt, inventory and use records, and (if personnel dosimetry is required) for personnel dosimetry reports.

7. Provide a personnel dosimetry program when required. Advise individual radiation workers of each high exposure report, and conduct an investigation to determine the cause of all overexposures to preclude a reoccurrence. Perform a quarterly review of occupational exposure to authorized users and workers to determine that the exposures are within the limits established by the ALARP program. Annually advise each user of their accrued dose.

8.Maintain a current inventory of the types, quantities, and locations of all radioactive material possessed, making sure the activity and types possessed never exceed license limits.

9.Make sure radioactive shipments are properly packaged and labelled according to IATA requirements, and that shipments are accompanied by proper shipping documents.

10. Instruct workers, who work or may work in or about the vicinity of the fixed gauge or gauges, of all applicable radiation safety rules and procedures 1) initially, 2) with every addition of new personnel, and 3) with each change in the radiation safety program.

11. Apprise management of the status of the radiation safety program and management’s responsibility for maintaining an adequate radiation safety program.

12. Take charge in all emergency situations (loss, theft, fire, explosion, etc.) to make sure correct emergency procedures are carried out, including notification. Also evaluate the situation that led to the emergency to reduce the chance of further problems.

13. Assure that radioactive materials are only used by, or under the supervision of individuals authorized by the licence.

14. Assure that radioactive materials are properly secured against unauthorized removal.

15. Maintain current operating and emergency procedures, including maintenance and lock-out procedures for work in and around fixed gauges.




8 Use

8.1 General Requirements The following requirements shall apply when using ionising radiation:

No practice shall be adopted unless its introduction produces a positive net benefit. All exposures shall be kept As Low As Reasonably Practicable (ALARP), economic and

social factors being taken into account. Radiation work shall have a minimum of 24 hours notice to enable sufficient time to plan

the work and conduct a site visit (Emergency work shall give sufficient time for planning) Individuals below the age of 18 years shall not be involved in radiological work. All operations involving the use of ionising radiation shall be carried out by a minimum of

two qualified radiological workers. Radiography crews (RT and X-ray) shall consist of two ASNT level II radiographers, one of which must be competent Radiation Protection Supervisor appointed by the RPA and Contractor management. An ASNT Level I radiographer may assist the Level II provided the latter has RPS qualifications.

Any work utilising radioactive sources carried out on behalf of PDO, or within PDO's Concession Area shall be carried out under an approved Permit to Work System (ref. PR-1172, "Permit to Work System Procedure Manual").

The PtW shall include: Details and planning of the work (pre-inspection is recommended) Completed Job HSE Plan i.e. a written risk assessment Radiation protection arrangements i.e. controls Emergency and recovery provisions in the event of an incident The Radiography Certificate for NDT work (ref: Appendix C) A sketch of the Controlled Area is required for NDT work

In addition, a number of simple methods are to be employed and shall be covered in general radiation protection training and site specific briefs to employees as follows:

In the case of X-ray radiography, using the minimum appropriate kV and mA settings;

Minimising time spent in the vicinity of the source of radiation or in areas where radiation levels are higher;

Maximising distance from the source;

Use of shielding where reasonably practicable.

Dose sharing is not to be used as a primary means of restricting exposure to individuals. Rather, priority is to be given to improving engineering controls and other means of restricting exposure, including changing the methods of work.

PDO and Contractors performing well logging using radioactive materials or generators shall comply with HSE Specification SP-1218, Well Engineering Specification for Radioactive Sources.

All site radiography, including operations with pipeline crawler equipment, shall be carried out in accordance with the IAEA Radiation Protection and Safety in Industrial Radiography, Safety Report Series No. 13, IAEA, Vienna (1999)

All medical uses of ionising radiation shall be carried out in accordance with the Medical and Dental Guidance Note 2002 published by the Institute of Physics and Engineering in Medicine. Note: The use of x-ray for medical images shall be exempted from the PtW and requirement and providing two qualified radiological workers.




8.2 Occupational Dose LimitsIonising radiation doses for individuals shall not exceed the levels stipulated in Table 1.

Table 1: Dose Limits

Classification Dose Limit (mSv/yr)

Reasoning

Maximum annual effective dose received from occupational exposure as a radiological worker (Ministry of Manpower)

(Ministry of Env. & Climate Affairs)

20

10

Limits Stochastic effects

Radiological workers are defined as any person who through their occupation may be exposed to an annual effective dose exceeding 2 mSv/year

2 Prevents continuous exposure of an individual close to the effective dose

limit

(For pregnant radiological workers) Maximum equivalent dose received from occupational exposure during entire term of pregnancy

1 Prevents continuous exposure to the foetus close to the effective dose

limit

Members of the Public or Non Classified Workers

1 Reduces exposures to ALARP

Notes:

1. The dose rate received by a radiological worker shall be measured using monitoring devices suitable for the type of radiation being monitored.

Table 2: Dose Action LimitsClassification Dose Limit

(mSv)Action

Annual effective dose received from occupational exposure as a radiological worker

5 mSv/yr Employer undertakes internal investigation (auditable by PDO,

Contractor or Regulator)

Three (3) monthly average effective dose received from occupational exposure as a radiological worker as measured from TLD or Film badge

3 mSv / 3 months

Managers shall be notified of dose received higher than normal

Monthly effective dose received from occupational exposure as a radiological worker as measured from TLD or Film badge

1 mSv/mth Managers shall be notified of dose received higher than normal

Any radiological worker who receives a dose exceeding 5 mSv shall be investigated by the Senior RPS and the reports available for audit by PDO, the Principal Contractor or Regulator. These limits are set to prompt managers to ensure the practice of dose restriction is in line with the As Low as Reasonably Practicable (ALARP) principle.




8.3 Dosimetric ControlDuring work, all radiological workers shall continuously wear a personal cumulative dosimetry (TLD or Film) badge sensitive to the type of ionising radiation to which they are exposed. Such badges shall be controlled by a recognised and competent dosimetry service, who shall provide the employer with reports on the dose received during the period of use of the badge and the cumulative annual and lifetime dose of the wearer.

Personal cumulative dosimetry badges shall be analysed on a fixed schedule as follows:

Monthly where the work environment is shown to expose workers to an average effective dose in excess of 2 mSv per year.

Quarterly where the work environment is shown to expose workers to an average effective dose below 2 mSv per year.

For any work where the cumulative exposure is likely to exceed 100 Sv in one day, radiological workers conducting the work shall carry, in addition to the cumulative dosimeter badge (TLD or Film), a personal cumulative audible alarming dose rate meter, which shall be controlled and reset after each work period. The readings for each day shall be recorded and kept on file.

8.4 Work Area Classification and Entry RestrictionControlled AreasAreas where the instantaneous effective dose rate may exceed 7.5Sv/h shall be designated as Controlled Areas. Access to these areas shall be controlled and they shall be clearly marked, cordoned off with the Trefoil radioactive warning and a written warning in English and Arabic. Only trained classified radiation workers shall be allowed access to these areas unless the work is assessed and can be performed safely under a written Job HSE plan incorporating a safe system of work (Risk assessment).

For example, during the period when well logging sources are removed from their shields, until the logging tool is downhole, access to the drill floor shall be restricted to the logging crew, engineer and Driller or Assistant Driller. Access below the drill floor shall be strictly restricted with appropriate signage.

Radiographers shall calculate the Controlled Area distance prior to the commencement of work and shall incorporate the Cordon-off distance into the Radiography Certificate. Radiographers shall always retreat beyond the Controlled Area to a safe distance where the doses are ALARP. Under no circumstances shall a radiographer be permitted to stand in the Controlled Area.

Supervised AreasAreas where the instantaneous effective dose rate may exceed 2.5 Sv/h, but not exceed 7.5 Sv/h, shall be designated as Supervised Areas. Entry into these Areas by Non-Classified workers shall only be permitted under a written Job HSE Plan incorporating a safe system of work (Risk Assessment).

Information, maps and plans indicating locations of usage and storage of radioactive materials shall be provided to the Royal Oman Police (Directorate of Civil Defence) and other concerned authorities in accordance with MD 249/97.

8.5 Instruments8.6.1 Portable Survey Meters




Portable exposure rate meters shall be provided suitable for the type of radiation used. They shall be light, robust and capable of being used in all weather under arduous conditions. The exposure rate meter can be scaled in millirem (mR) per hour or microsieverts (μSv) or millisieverts (mSv) per hour, however preference is given to SI units.

Special monitors are required to detect neutrons. All slow them down in a sphere of polyethylene with generally a Boron Triflouride proportional counter in the centre. Ordinary detectors that are suitable for X-rays, gamma rays and even beta particles must not be used to detect neutrons. In the event of an incident involving a neutron emitting source, to enable calculation of the permitted exposure time, a neutron survey meter shall accompany all neutron emitters e.g.Am/Be-241. Note: not all meters are intrinsically safe and may require a Hot Work permit in facilities or working around hydrocarbons. Calibration of instruments shall be conducted by a qualified person every 12 months and include a test certificate from the date of the test.

The employer is responsible for ensuring that sufficient numbers of meters are provided for the work to enable calibration, servicing and repair to meters and increased work load.

8.6.2 Audible Alarms (Bleepers)Audible alarms are small light weight, designed to be carried in the top pocket of a coverall. They must be kept switched on during the entire period that the wearer may be exposed to high output sources. These shall be able to indicate the presence of radiation by an audible signal immediate warning of a high dose rate. They shall also be capable or emitting a recognizable signal at a dose rate of 100 uSv/h.

8.6 TrainingMD 249/97 requires that all classified radiological workers and drivers of radioactive sources must be suitably trained and this training recorded e.g. in the HSE Passport. Accordingly, all radiological workers and drivers shall be adequately trained for the job to which they are assigned and include refresher training as a minimum every three years.

Specific training to a recognised standard by the RPA or equivalent shall be given to all persons whose work involves the handling of unshielded sources and the operation of X-ray or neutron generators.

Radiological workers shall be fully acquainted with the requirements of this Specification and should be fully aware of the potential hazards arising from the presence of radiation at the storage site, during transportation or at the work site.

Such workers include, but are not limited to:

NDT radiographers (Gamma and X-ray) Medical X-ray radiographers Well logging engineers (Neutron and Gamma) Multiphase and profiler instrument technicians

8.7 Medical ControlPre-employment medical examinations of all radiological workers shall include, in addition to the standard Visa requirements a detailed medical examination in accordance with SP-1230 "Medical Examination, Treatment and Facilities": It is now accepted that medical surveillance




of radiation workers should follow the same general principles of occupational medicine as applied to other groups of workers.

In most cases the actual exposure to Ionising Radiation is small that it will have little influence on decisions regarding medical suitability for employment. The emphasis has moved to encompass the fitness to work aspect of the medical assessment.

The requirements for adequate medical surveillance comprise of:

A pre-employment medical examination before first being designated as a classified radiological worker; A complete occupational history, including all previous exposures to ionising radiation and a review of the previous exposure (TLD/Film) records; An assessment whether the radiation is electrically generated or from sealed or

unsealed radioactive materials and Type (alpha/beta/gamma/neutrons/X-rays) Special medical surveillance of an employee when a relevant dose limit has been

exceeded (based on advice from the RPA); Any test specifically recommended for radiological workers by PDO's Chief Medical

Officer or Company approved physician A review of health after cessation of work where this is necessary to safeguard the

health of the individual

All radiological workers shall undergo an annual medical examination at the employers expense in a PDO approved clinic. The employer shall provide the examining medical practitioner with the worker's occupational dose history since the previous medical examination. Women of child reproductive capacity should receive advice about the risks to the foetus and nursing infant arising from exposure to ionising radiation and the need to notify the employer in writing and without delay if they become pregnant.

Chest X-rays should not be carried out as part of the initial examination or periodic reviews unless there is a clinical reason for doing so. Full blood count tests need only be conducted if there is a clinical indication or as required in SP-1230. Should an employee receive a dose from x-rays, gamma rays or neutrons exceeding 250 mSv blood testing is mandatory. Further advice may be sought from Guidance for Appointed Doctors. The Ionising Radiation Regulations 1999 Health and Safety Executive United Kingdom (Revised 2003)

8.8 Design and Use of Shielded Enclosures (Fixed Facilities)For permanent radiography locations e.g. ODC/EMC workshops and major projects with site spool fabrication, it is strongly recommended that a purpose built enclosure be constructed to enable radiography (gamma and x-ray) be performed safely outside of the contractors workshop without interruption. A properly designed and operated shielded enclosure will help keep radiation exposures of radiographers below 5 mSv (or less) per year. In other cases local shielding is to be used as far as reasonably practicable.

The general design is similar for all enclosures, although different characteristics are incorporated depending on whether the enclosure is to be suitable for X-ray, accelerators or gamma radiation equipment. Designs to shielded enclosures require guidance in terms of anticipated doses, dose rates and exposure times. Design considerations for these installations include: (a) shielding considerations, (b) personnel access door interlocks, (c) fixed radiation monitors, (d) warning signs and symbols and (e) emergency stops.




9 DisposalWaste shall be classified as radioactive waste material if its activity is higher than 100 Bq/g.

Radioactive waste differs from all other types of waste. Its radioactivity decreases only with time, and its radioactive properties cannot be altered or destroyed by any physical, chemical or biological treatment.

Sealed sources and tracer applications account for most of the industrial use of radioactive substances. There is almost no waste disposal required in the use of sealed sources, except for disposal of the source upon decay of its radioactivity to levels at which it can no longer be used. Damage to the sealed source may result in radioactive waste in the form of contaminated equipment, packing, clothing and other accessories.

Radioactive waste material shall be classified as hazardous waste, and shall be handled and disposed of in accordance with the requirements of SP-1009 “Waste Management" and MD249/97.

The owner or custodian of the source shall maintain records to demonstrate safe return and disposal of the radioactive source once beyond the effective use of the source or contract expiry. No sources shall remain in the PDO location beyond the completion of an existing contract with PDO. The Project Manager, Contract Holder or nominated Company Site Representative is responsible for ensuring all sources are removed and properly disposed.

9.1 Abandonment of Radioactive Materials (stuck in-hole while logging)The ultimate decision to abandon a radioactive material rests with the Asset Manager after consultation with the Senior Well Engineer and Corporate Radiation Focal Point. Abandonment of radioactive materials down hole shall be performed in accordance with HSE Specification SP1218 – Well Engineering Specification for Radioactive Sources.

The abandonment of the radioactive material shall be reported to the authorities via MSE/2, who shall provide advice about the information required. A letter by the Asset Owner and MSE/2, accompanied by the completed “Abandoned Source Template”, shall be sent to the Ministry for Environment and Climate Affairs (MECA).




10. Emergency Response

The following occurrences shall be reported in accordance with HSE/97/01 “Incident Notification, Investigation, Reporting and Follow-Up" to the Project Manager, Contract Holder or Main Contractor in the case of sub-contractors.

Any loss of radioactive material (including temporary loss or stuck logging tools). Loss or theft of a source of ionising radiation Vehicular accident involving transport of sources of ionising radiation Accidental separation of a chemical source from its shielding Physical damage to a sealed source, causing leakage of radioactive material Contamination of the environment with radioactive material Any exposures greater than the Dose or Action Limits listed under Section 8.3.

The MECA shall be notified of the following occurrences:

Before the import and use of radioactive materials, or any other relevant work in the Sultanate.

If there is any release of radioactive materials in excess of that specified in the permit. If any person or worker receives a radiation dose greater than the level indicated in the

permit, MD249/97 or the Ministry of Manpower Occupational Health and Safety Regulations in the Private Sector.

Formal Contingency Plans shall be prepared to respond to any emergency which might arise from the storage and handling radioactive materials including incidents outlined above. Written emergency procedures shall be documented in the Radiation Safety Manual of the contractor and shall align with PDO's Emergency Response Documents.

All users of ionising radiation shall have available at all times the necessary means to contact their RPA, Senior RPS and PDO local emergency services when operating outside their normal base of operations.

Contractors shall have planned emergency mock drills to demonstrate that radiological workers and others such as the ROP, first aid responders or fire and emergency crews have sufficient experience and confidence to handle emergencies.




11. References11.1 Ministry of Environment and Climate Affairs MD249/97 and Supplement 2003

11.2 Ministry of Manpower Occupational Health and Safety Regulations in the Private Sector

11.3 International Atomic Energy Authority (IAEA) Safety Series TS-R-1 Regulations for the Safe Transportation of Radioactive Materials 2009

11.4 Shell Safety and Health Committee “Ionising Radiation Safety Guide” November 1993

11.5 PDO SP1218 - Well Engineering Specification for Radioactive Sources November 2007

11.6 PDO PR1712 - Permit to Work System Manual Revision 6.1 December 2008

11.7 PDO PR1418 – HSE Procedure Incident Notification, Analysis, Reporting and Follow-up Revision 2.1 July 2009

11.8 Guidance for Appointed Doctors. The Ionising Radiation Regulations 1999 Health and Safety Executive United Kingdom (Revised 2003)




Appendix A Radioactive Source Consignment NoteTo be completed when transporting a radioactive source from Muscat to the interior location and upon return to Muscat for interim storage and disposal.

Section A – Source Details

To be completed by Consignor

Company Name:

Address:

Emergency Contact Numbers:

Proper Shipping Name:

Class Number(s) UN No.

Name of Isotope

Type of source: Sealed ( ) Unsealed ( )

Activity (GBq or Ci)

Serial Number:

Package Category Transport Index:

Section B Transportation DetailsCompleted by Consignor

Consignor name:

Destination including stops:

Transport Contractor Name:

Contact Numbers (mobile):

I hereby certify that the package containing radioactive material has been properly packed, marked and labelled, and as such is in conformity with the relevant Regulations for the Safe Transport of Radioactive Materials, including provision of a TREMCARD.

Consignor Signature: Date:

Section C Completed by Consignee (Receiver)

Consignee Name:

Designation / Ref. Ind.

I hereby certify that the consignment containing radioactive material(s) has been inspected and monitored to verify it contains the source and is without damage.

Signature: Date:




Notes:

This form is an example of the Transport Documents required for shipping and transporting Dangerous Goods in Oman by Road in accordance with the IAEA Regulations for the Safe Transport of Radioactive Materials. Contractors transporting source shall establish their own forms which shall be completed in triplicate as follows:

1st copy (completed and kept by consignor)

2nd copy (completed and kept by receiver)

3rd copy (returned to consignor by receiver)

The Consignor and Consignee shall be radiological workers

Transporters shall be licensed by the ROP for carrying radioactive materials

All vehicles carrying radioactive materials shall be occupied by at least two people, one of whom shall be a radiological worker




Appendix B – Storage Facility Design










Appendix C – Radiography Supplementary Certificate




This page was intentionally left blank

