ASNT Inspection Procedures - 08 - Industrial Radiography PDF

U.S.
NRC
UNITED STATES NUCLEAR REGULATORY COMMISSION
HRTD
Protecting People and the Environment
Human Resources
Training & Development
Industrial Radiography
G-108 – Inspection Procedures March 2011- Slide 1 of 88

Radiography Topic Outline
¾ Overview
¾ Photo Tour
¾ Regulatory Issues
¾ Office and Field Inspections
¾ Violations
¾ Accidents

Overview
¾ Industrial radiography (IR) is a method of

nondestructive testing (NDT)
¾ NDT is just what its name implies:

TESTING WITHOUT DESTROYING
¾ NDT is any method of examining an object or material

which doesn’t impair its future usefulness
¾ Also known as:

¾ NDE (nondestructive examination)
¾ NDI (nondestructive inspection)
Overview
Industrial Radiography Definition
¾ An examination of the structure of materials by

nondestructive methods, utilizing ionizing radiation
to make radiographic
g p images
g

Overview
Radiographers are NDT technicians/inspectors
Principal NDT Disciplines:
RT – Radiographic
g p Testing
g ((the onlyy pportion yyou will be inspecting)
p g)
UT – Ultrasonic Testing
PT – Penetrant Testing
MT – Magnetic Particle Testing
ET – Eddy Current Testing
VT – Visual Testing

Overview
Manufacturers must assure that their products meet

standards of reliability, durability & safety - NDT provides
essential QA/QC tools to industries
Where is NDT Used?
¾ Aerospace ¾ Marine
¾ Aircraft ¾ Security
¾ Automotive ¾ Metals & Non-Metals
¾ Casting & Forging ¾ Nuclear power plants
¾ Chemical & Petroleum ¾ Transportation
¾ Construction ¾ Utilities
¾ Electronics ¾ Offshore applications
¾ Food Processing ¾ Pipelines
Overview
NDT technicians obtain certification through

qualification procedures developed by the American
Society for Nondestructive Testing (ASNT)
Level I – qualified to perform test

Level II – qualified to evaluate test results
Level III – qualified to evaluate others’ results

Overview
¾ ASNT NDT certification is unrelated to radiation

safety; it focuses on certification that the technician
can perform and/or read the results of the non-
destructive test that was performed.
¾ However, ASNT does offer radiographer radiation

safety certification (RAM, x-ray & combination certs)
to satisfy NRC & State certification requirements

PHOTO TOUR

Equipment Overview

Equipment and PPE
OSHA-compliant PPE:
¾ Hardhat TLD / OSD /
¾ Steel-toed boots
¾ Safety glasses
¾ Hearing protection

192Ir Radiography Cameras
QSA Global (Sentinel)

Models 660 and 880
Industrial Nuclear Co.
Model IR-100
Source Production
& Equipment Co.
Model SPEC-150
60Co Radiography Cameras
Sentinel Model
680B
(previously AEA)
SPEC Model SPEC-300

Associated Equipment
Clamps, collimators, &

source guide tubes
Tungsten
Drive cables collimator

Radiographic Equipment

Source Changers
AEA Model 650L
AEA Model 650 cut open

to reveal interior design

Transport/Storage Containers
AEA overpack
Shipping drum for INC IR-100

(convenience overpack)

Permanent
Radiographic Installation
(Equipped with industrial x-ray machine)

Field Radiography “Rig”
Pickup truck with portable

darkroom mounted on
back & full complement of
equipment - standard for
radiography at field sites

Work Sites
Work site problems can

include
¾ the environment (weather,

noise, fumes, etc)
¾ accessibility and physical
safety
¾ lighting
¾ difficulties in controlling
site access (site
boundaries)

Work Sites
Work site problems can

include
¾ getting the equipment to

the site and securing it
¾ lengthy exposure times
¾ difficulty in ensuring
worker protection

Field Radiography
Gas Pipeline Welds

Radiographic Operations
Setting up to
shoot the weld

Posilock
Release
Cranking out Using distance

the source & shielding
Survey after a shot

Retracting source
following shot
Returning
equipment
to storage
in truck
Surveying camera

REGULATORY ISSUES

Regulatory Issues
Question
What makes industrial radiography inspections

important & what makes them different from
inspections of other licensed activities?
Answer
¾ The radiography industry has a poor safety record

¾Many regulatory requirements to comply with
¾Highly radioactive sources used
¾Harsh working conditions to deal with
¾ The public, as well as radiographers, are at risk
¾ In an accident, radiation exposures may be high
Risk Ranking of
Licensed Activities
Relative
Risk Ranking Activity
Highest 1) Industrial Radiography - field
2) Medical - therapy
3) Medical – manual brachytherapy
4) Medical - teletherapy - single source
5) Industrial Radiography – permanent
radiographic installation
Industrial radiography holds the no. 1 & no. 5 spots

on the NRC’s risk ranking list
Source: U.S. NRC NUREG/CR-6642, Vol. 2 (2/00)

Regulatory Objectives
¾ To ensure that radiographic operations are being

performed in a manner that does not result in undue
risk to workers, the public or the environment
¾ To ensure compliance with regulatory requirements

& license conditions

Regulatory Objectives
Regulatory Objectives are accomplished by:
¾ Licensing “A regulation without

adequate inspection
is like posting a speed
¾ I
Inspection
ti limit sign without having
police to enforce it.”
¾ Investigation
¾ Enforcement

NRC Inspection Procedure 87121
Industrial Radiography Programs
Contents
87121-01 Inspection Objectives

87121-02 Inspection Requirements
87121-03 Inspection Guidance
87121-04 References

Inspection Focus Elements (FEs)
Condensed Version
FE-1: Control of RAM (security & accountability)

FE-2: Adequate RAM shielding
FE 3 Limit
FE-3: Li it h
hazards
d tto RAM
FE-4: Appropriate dosimetry
FE-5: Proper radiation Instrumentation
FE-6: Trained & empowered workers
FE-7: Appropriate management oversight &
program/personnel audits

FE-1: RAM Security &
Accountability
¾ Control of RAM at permanent facilities not a significant problem;
cameras rarely stolen from licensees’ offices (but still important
to evaluate security, as break-ins have occurred, even to posted
RAM storage areas)
¾ IR security
y at temporary
p y jjob sites a moderate p
problem; cameras
have been stolen, but accidental loss is more common
¾ NRC has issued orders for the increased security of radiography

sources and other sources at or above the Quantities of Concern
as well as Orders requiring fingerprinting as part of a background
investigation for persons granted unescorted access to these
materials (EA 05-090 and EA 07-305, respectively)

FE-2: Adequate RAM
Shielding
¾ Moderate to high potential for compromises to camera
shielding
¾ Loss of shielding can occur if source becomes

disconnected or otherwise fails to return to
shielded position during operations; results from
operator error, equipment failure, or both
¾ Shielding can be damaged if dropped from a

sufficient height, though potential for release is
low

FE-3: Limit Other Hazards
to RAM
¾ Moderate potential for other hazards
¾ For example, industrial radiography source

exploded at a Louisiana refinery when an
ungrounded electrical line contacted the drive
cable
¾ Unexpected movement of a pipe laybarge while

performing radiography caused the exposure
device to fall and kink the guide tube, preventing
the source from being retracted for 5 hours

FE-4: Proper Dosimetry
¾ Personnel required to wear whole body personal

monitoring badge, pocket dosimeter & alarming rate
meter; IMPORTANT for crews to use personnel
monitoring equipment properly
¾ Personnel monitoring is the key performance

indicator for industrial radiography licensees;
continued high badge readings is indicative of poor
ALARA practices (time, distance, shielding) while
performing radiography in the field.

FE-5: Proper Radiation
Instrumentation
¾ High potential for problems
¾ Survey meters may be un-calibrated, have dead

batteries, be damaged, or be unavailable
¾ Same goes for alarming ratemeters
¾ The survey meter and alarming rate meter are the two
main instruments that will tell a radiographer that
something is wrong (source is not fully shielded when
they think it is).

FE-6: Trained &
Empowered Workers
¾ Licensee may have a weak safety culture that
tolerates poor safety practices in the field
¾ Even trained & experienced workers can become

complacent especially with extreme working
complacent,
conditions (weather, location of work, etc…)
¾ Production pressure can lead to shortcuts and

accidents
¾ Radiographers are not typically very empowered

FE-7: Appropriate management oversight
& program/personnel audits
¾ Management oversight & participation in the

Radiation Protection program (RPP) is crucial to a
positive safety culture in the field
¾ Program & performance audits (such as those

required every six months for radiographers and
assistants/trainees) are very important, but can be
ineffective if not performed unannounced
¾ Licensees should understand that deficiencies

identified and documented during these audits are
not cited as violations when reviewed during an
inspection
CONDUCTING
INSPECTIONS

Field versus Office Inspections
¾ Field inspections offer better opportunity to evaluate

licensee performance
¾ Field inspections are likely to identify more serious

violations than mere paperwork issues
¾ Extra effort is required to conduct field inspections;

you should always ask what jobs are ongoing during
the office inspection, so that you can attempt to
perform a field inspection as well

Conducting Office Inspection
Records Review
¾ Utilization logs ¾ Initial and refresher training

¾ Dosimetry records records
¾ Calibration records ¾ Audit records (annual RPP
¾ Leak test records & 6-month field audits)
¾ Survey reports/records ¾ Equipment records
¾ Inventory records ¾ O&E Procedures
¾ Receipt/transfer records ¾ Part 21 notification reports

Conducting Office Inspection
¾ Records Review (cont)
¾ Permanent radiographic installation safety

system check records
¾ Current copies of RAM license
¾ Current copies of applicable NRC or Agreement
State regulations
¾ Posting of “Notice To Employees”
¾ Posting of “Notice” with locations of required
documents
¾ Posting of “Section 206” of the Energy
Reorganization Act of 1974
Frequent Violations from
Office Inspections
¾ Training & training records (HAZMAT, refresher, etc…)
¾ Surveys (failed to perform, inadequate records)
¾ Leak testing (failed to perform, inadequate records)
¾ Personnel monitoring (failed to perform, dose limit exceeded)
¾ I t
Instrument t calibrations
lib ti
¾ Reporting of events required by 10 CFR 30.50 & 34.101
¾ Posting of signs in storage area
¾ Quarterly inventories
¾ Internal audits (annual program reviews, field audits)
¾ RSO changes (gone, replaced, not functioning)

Equipment Inspection
Lock Assembly Source

General Guide Tube
¾ Radiation survey
¾ Labels
¾ Outlet port End Stop
Crank
¾ Lock mechanism
¾ Source assembly
Control Sheaths
connector
¾ Protective
caps/plugs
Drive Control

Daily Inspection – Guide Tube
Source Tube Inspection
¾ Fittings
¾ Dents or depressions
¾ Thermal damage
¾ Cuts or tears
¾ Source stop (endcap)

Daily Inspection – Drive Cable
Control Assembly
¾ Connectors
¾ Dents or depressions
¾ Th
Thermall damage
d
¾ Cuts or tears
¾ Hand crank
¾ Inspect the drive cable
¾ Freedom of movement
¾ Check for corrosion
¾ Ensure wires have not frayed
Daily Inspection
Source Connector

Improperly Maintained Equipment
¾ Inadequate inspection and maintenance led to this

drive cable being used in a worn condition.
¾ The cable subsequently broke leading to an accident

and action to retrieve the detached source

Conducting Field Inspections
¾ Unannounced vs. announced inspections
¾ Use of licensee utilization logs and licensee

customer contacts for inspection planning and
scheduling
¾ Observations on jobsite
¾ Observe licensee without their knowledge

¾ Determine the status of work in progress
¾ Minimize impact to licensee’s operations

¾ Observations on jobsite (cont)
¾ Radiation detection equipment (available,

calibrated, properly functioning)
¾ Area control (continuous control of area)
¾ Posting (RA and HRA)
¾ Radiation surveys (after each exposure and
boundary surveys)
¾ Procedures (visual surveillance of operation,
ALARA, camera locking)
¾ Paperwork (filled-out and complete)

¾ Interviews: try to interview all personnel together

¾ Try to approach operation from truck towards
radiographers
¾ Equipment status: camera secured, or in use
¾ Equipment inspection
¾ Personnel monitoring device
¾ Radiography cameras
¾ Survey meters
¾ Alarming ratemeters
¾ Pocket dosimeters

¾ Equipment inspection (cont)
¾ Associated equipment use (guide tube, endcap)

¾ Posting & barricade use
¾ Ensure that the lock on the darkroom door is
operable

¾ Personal safety equipment examination
¾ Check personal monitoring device for all

personnel for proper wear period
¾ Check pocket dosimeters for all personnel
personnel,
including calibration date and current dose
¾ Check alarming ratemeter to ensure operability
(paperclip method)

¾ Training of personnel
¾ Determine who is a radiographer and who is a

radiographer’s assistant (trainee)
¾ Ask to see radiographer
radiographer’s s certification (wallet
cards)
¾ Ask all personnel when was the last time they
had radiation safety training

¾ Procedures
¾ Availability of O & E Procedures

¾ Licensee personnel familiarity with procedures
¾ Licensee personnel aware of current emergency
contact information
¾ Determine particulars of radiography to date
¾ Ask licensee personnel to describe transport of
exposure device(s)
¾ Determine licensee’s schedule for remainder of
job

¾ Daily radiation report should contain:

¾ Pocket dosimeter start readings (not always
zero)
¾ Restricted area survey (2mR boundary)
¾ Survey instrument & calibration date
¾ Exposure
E d i & activity
device ti it off source
¾ Equipment inspection list
¾ Other information that should be available

¾ Source decay chart (current leak test)
¾ Shipping papers
¾ Copy of License they are working under

¾ “Notice to Employees” posted in darkroom
¾ Current O&E Procedures available
¾ Perform your own confirmatory surveys
¾ Unrestricted area boundary if possible

¾ Posted radiation areas (RA)
¾ Camera in storage in radiography vehicle
¾ Camera survey

VIOLATIONS

Frequent Violations From
Temporary Jobsite Inspections
¾ Surveys (full circumferential survey not

performed, 2mR boundary not checked)
¾ Personnel monitoring (No TLD, ARM, SRPD)
¾ Shipping papers
¾ Instrumentation calibrations
¾ Posting of CRA & CHRA signs
¾ Unrestricted area radiation levels (>2mR in any 1
hour)
¾ Unsecured storage or unattended RAM
¾ Overexposures

ACCIDENTS

Gamma Radiography
Emergencies
¾ Have a high potential for serious injury or death.
¾ Most common overexposure is to extremities

during accident condition
¾ Proper surveys can prevent serious injury from an

emergency
¾ The lack of appropriate surveys accompanied by

the absence of an operable ARM are usually a
contributing cause to all radiography
overexposures
Types of Accidents
¾ Failing to fully retract the source into the shielded

container combined with a failure to properly use
a survey meter to verify the source location.
¾ Damage to the guide tube resulting in a source
jammed
ja ed in tthe
eeexposed
posed pos
position.
to
¾ Source disconnected from the control cable (wear
and tear, inadequate maintenance)
¾ Theft or loss of source and/or device (fairly rare)
¾ Malfunction or defeat of a safety system
¾ Contamination due to a leaking source (rare)

Probable Accident Situation
Source hang-up
¾ crushed or dented
guide tube
¾ control malfunction
¾ camera malfunction
¾ damaged S-tube (DU?)

- drive cable crimped or
caught on edge

Source disconnect
¾ Connector mis-connect
¾ Fouled connector lock
¾ Wear in the connector
¾ Damaged isotope connector
¾ Manufacturing or design flaw
¾ Human error
¾ Broken control cable connector

¾ Source stop malfunction

A source may be lost or stolen if it is
¾ left unattended at a job site
¾ stored in a vehicle and the vehicle is stolen
¾ not properly secured within the vehicle and falls

off during transport (most common)

Accident Examples
An assistant radiographer was overexposed due to a

detached source left in the guide tube
¾ No radiation surveys were made after each

exposure and therefore the users did not detect
that the source had not been returned to shielded
container
¾ The assistant radiographer disassembled the

equipment after the last exposure and carried the
guide tube (with the source) around his neck to the
next location

Accident Examples
An exchange of sources results in a source assembly

being pulled from the shielded container
¾ The radiographer failed to read the Operations

Manual for the source changer
g
¾ The radiographer did not follow the procedures in

the Operations Manual because he thought he
knew how the source changer operated

Accident Examples
A source capsule was worn through, resulting in

contamination at the work site
¾ The wear through occurred due to improper

maintenance
¾ Excessive grit remained in the container and

guide tubes to act like sandpaper on the capsule
¾ Such wear and tear of a source capsule is not

common

Radiography Overexposures
Note: The following slides

show graphic injuries
sustained by individuals
involved in radiography
accidents. These imagesg
are not intended to upset
you, but are intended to
demonstrate the serious
consequences of failure
to follow procedures and
the importance of doing
thorough inspections

Industrial Radiography Accidents
1979
Overexposure
Victim
31 days
50 days
19 months

Industrial Radiography Accident
(22K – 30K rem extremity dose)
14 d
24 d
27 d

padding since any

contact very painful 56 d 102 d
skin g
graft
temporary relief
at 5 years
persistent pain
leads to
multiple
amputations
¾ IAEA Safety Report

“Lessons learned from
Accidents in Industrial
radiography” Series
No 7:
No.7:
¾ 43 cases; 9 involving the

public or other non-
radiation workers

Severe injury to a non-radiation

worker resulting from a
radiographer failing to use a survey
meter to confirm the source had
been returned to the shielded
container
¾ 185 GBq (5 Ci) 192Ir source in

shirt pocket for 90 min
¾ estimated skin dose 30 Gy
(3,000 rad)
Day 15
¾ whole body 2-5 Gy (200-500 rad)
Yanango, Peru 1999
¾ 1.37 TBq (37 Ci) 192Ir
¾ 2 days after accident;

blister on upper thigh

Case Study
NRC PNO-III-02-019 May 1, 2002
¾ 1,500 rem to lower leg from 81 Ci 192Ir source
¾ AR inoperable (battery) - did not look at survey meter
¾ Changed film - source in guide tube
¾ Survey meter and pocket dosimeter off
off-scale
scale
¾ Did not inform supervisor
¾ 2 weeks later developed skin redness on left calf
¾ Over next year, wound ulcerated and wouldn’t heal
¾ Physician diagnosed potential radiation injury
¾ Licensee informed - reported to State
Case Study
NRC PNO-III-02-019 May 1, 2002

Lessons Learned
¾ A review has been performed of a number of

industrial radiography accidents to determine the
causes and the lessons learned
¾ The following lessons provide guidance on how

accidents can be prevented.

Adhering to Procedures
Worker did not follow established procedures,

specifically did not perform the required radiation
surveys to verify the source had returned to the
shielded position
¾ Inadequate supervision
¾ Actions taken were deliberate

Poor Safety Culture
Management focus not on safety
¾ Lack of care and maintenance of the equipment

used
¾ Complacency in personal safety resulting in harm

to others
¾ Inadequate resources to perform required jobs

Management Control
Management control lost at a radiography facility
¾ Individuals allowed to operate without proper

training
¾ Failure to detect poor work practices of workers

Training
No training given to personnel prior to using the

equipment
¾ Training inadequate in basic radiation safety

principles
¾ Training in the practical use of the equipment

inadequate
¾ Safety training not ingrained; mistakes made if

adverse or unexpected conditions encountered

Conclusion
Importance of a good, thorough inspection of Industrial

Radiography activities, particularly field operations
¾ Bad things can happen
¾ When bad things happen, someone can be very

seriously injured or worse
¾ It’s the licensee’s responsibility to do the right

thing, but a good inspection can determine if the
licensee knows what they are doing and whether
they really care about radiation safety

THE END

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G-108 – Inspection Procedures March 2011- Slide 1 of 88

¾ Office and Field Inspections

G-108 – Inspection Procedures March 2011- Slide 2 of 88

¾ Industrial radiography (IR) is a method of

¾ NDT is just what its name implies:

¾ NDT is any method of examining an object or material

¾ Also known as:

Industrial Radiography Definition

¾ An examination of the structure of materials by

G-108 – Inspection Procedures March 2011- Slide 4 of 88

Radiographers are NDT technicians/inspectors

Principal NDT Disciplines:

G-108 – Inspection Procedures March 2011- Slide 5 of 88

Manufacturers must assure that their products meet

NDT technicians obtain certification through

Level I – qualified to perform test

G-108 – Inspection Procedures March 2011- Slide 7 of 88

¾ ASNT NDT certification is unrelated to radiation

¾ However, ASNT does offer radiographer radiation

G-108 – Inspection Procedures March 2011- Slide 8 of 88

G-108 – Inspection Procedures March 2011- Slide 9 of 88

G-108 – Inspection Procedures March 2011- Slide 10 of 88

G-108 – Inspection Procedures March 2011- Slide 11 of 88

QSA Global (Sentinel)

SPEC Model SPEC-300

G-108 – Inspection Procedures March 2011- Slide 13 of 88

Clamps, collimators, &

G-108 – Inspection Procedures March 2011- Slide 14 of 88

G-108 – Inspection Procedures March 2011- Slide 15 of 88

AEA Model 650L

AEA Model 650 cut open

G-108 – Inspection Procedures March 2011- Slide 16 of 88

Shipping drum for INC IR-100

G-108 – Inspection Procedures March 2011- Slide 17 of 88

(Equipped with industrial x-ray machine)

Pickup truck with portable

G-108 – Inspection Procedures March 2011- Slide 19 of 88

Work site problems can

¾ the environment (weather,

G-108 – Inspection Procedures March 2011- Slide 20 of 88

Work site problems can

¾ getting the equipment to

¾ lengthy exposure times

G-108 – Inspection Procedures March 2011- Slide 21 of 88

G-108 – Inspection Procedures March 2011- Slide 22 of 88

G-108 – Inspection Procedures March 2011- Slide 23 of 88

Cranking out Using distance

Survey after a shot

G-108 – Inspection Procedures March 2011- Slide 27 of 88

G-108 – Inspection Procedures March 2011- Slide 28 of 88

What makes industrial radiography inspections

¾ The radiography industry has a poor safety record

Industrial radiography holds the no. 1 & no. 5 spots

Source: U.S. NRC NUREG/CR-6642, Vol. 2 (2/00)

¾ To ensure that radiographic operations are being

¾ To ensure compliance with regulatory requirements

G-108 – Inspection Procedures March 2011- Slide 31 of 88

Regulatory Objectives are accomplished by:

¾ Licensing “A regulation without

G-108 – Inspection Procedures March 2011- Slide 32 of 88

Industrial Radiography Programs