ukcssop004_iss1am01

Working with Radioactive Materials UKCS-SOP-004
Contents
Authorisation for Issue

Amendment Record
Amendment Summary
Distribution List
Preface
List of Abbreviations
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Part 1 Sealed Sources, Radiation Generators and

Unsealed Radioactive Material (Radiotracers)
Part 2 Low Specific Activity (LSA) and Naturally
Occurring Radioactive Material (NORM)
Addendum 1 References
Addendum 2 Procedure in the Event of a
Lost Radioactive Source in a Well
March 2002 Issue 1/AM01 i/ii

Authorisation for Issue
Issue Authority
Name: John Watson
Signature: ________________________________________________
Date: ________________________________________________
Position: Operations Delivery Team Leader, GFU

Uncontrolled
Technical Authority
Name: Mike George
Signature: ________________________________________________
Date: ________________________________________________
Position: HSE Team Leader, UK and Faroes Exploration, UKX&F
November 2001 Issue 1 iii/iv

Amendment Record
For Audit Use

Amendment Incorporated By
Checked
Number
Name Signature Date Signature Date
Uncontrolled
AMOSAF.171
November 2001 Issue 1 v/vi

Amendment Summary
Issue No Date Description

Issue 1 November 2001 First issue.
Issue 1/AM01 March 2002 Addition of outline guidance concerning reporting
the loss of a radioactive source in a well in UKCS.
Distribution list updated.
Uncontrolled
March 2002 Issue 1/AM01 vii/viii

Distribution List
Holders of Controlled Hard Copy
Copy Copyholder Location
01 Data Control Centre (DCC) ODL, Aberdeen
Virtual Copyholders
Copy Copyholder
Uncontrolled
01 Document Issue Authority (John Watson)

02 Document Technical Authority (Mike George)
03 Graham Wales, Synetix, Bridge of Don, Aberdeen
04 EoS Document Controller (Dave Taylor)
05 EoS Operations Excellence HSE Consultant (David Egan)
06 OOE, Magnus
07 OTL, North West Hutton
08 OTL, Thistle
09 Thistle/NWH Field Support Team Leader (Colin Browning)
10 BSG SMS Co-ordinator (Peter Malcolm)
11 MNS SMS Co-ordinator (Peter Faulkner)
12 MNS SMS Co-ordinator (Peter Thompson)
13 MNS SMS Co-ordinator (Carl Thomessen)
14 MNS SMS Co-ordinator (Justin Haigh)
15 CNS SMS Co-ordinator (Jim Blacklaws)
16 NBU SMS Co-ordinator (David Robertson)
17 NBU EPU SMS Co-ordinator (David Egan)
18 NBU SMS Co-ordinator (John Beaumont)
19 NSI SMS Co-ordinator (Ann Rosbrook)
20 SBU SMS Co-ordinator (Malcolm Watson)
21 SBU SMS Co-ordinator (Simon Robinson)
22 MNS SMS Co-ordinator (Bruce Morrison)
March 2002 Issue 1/AM01 ix/x

Preface
Purpose
The use of ionising radiations from radioactive material in the form of sealed sources and as
unsealed material is an ever-present beneficial feature of oil exploration and production
operations. An indication of their widespread use is given overleaf.
The presence of process scales and sludges contaminated with naturally occurring
radioisotopes, extracted from the producing reservoir under particular operational conditions,
is a much less desirable situation and requires significant resources for the management and
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control of the problems resulting from the presence of such material.

For either of the above scenarios, where ionising radiations are a feature of the working
environment, clear and concise working practices must be developed and implemented to
reduce the potential exposure to ionising radiation of those working with the material, or in the
area, and to minimise the effects on the environment from any subsequent disposal of the
radioactive material.
Radiation protection is based on three principles recommended by the International
Commission on Radiological Protection (ICRP) and is described below. Relevant national
legislation incorporates these principles into appropriate statutory documents.
• Justification
Every practice resulting in exposure to ionising radiation shall be justified by the advantages
it produces.
• Optimisation
All exposures shall be kept As Low As Reasonably Achievable (ALARA), economic and social
factors being taken into consideration.
• Dose Limits
The sum of all doses received shall not exceed certain limits.
The procedures or local rules contained in this manual employ these principles and, if correctly
applied, will ensure that all exposures to ionising radiation and therefore all associated risks are
kept ALARA.
This document is arranged for use as a working document with the facility for filing
statutory notifications and appointments.
November 2001 Issue 1 xi

UKCS-SOP-004 Working with Radioactive Materials
The Use/Occurrence of Radioactive Materials in the

Oil Production Industry
The following list is illustrative only and is not intended to be exhaustive.
Sealed Sources
• Non-destructive Testing (NDT)
− Radiography
• Nucleonic instrumentation
− Vessel level and interface measurement
− Cement, mud and process flow density measurement
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• Well operations
− Gamma and neutron source downhole logging
− Depth identification by casing markers (pip tags)
− Measurement While Drilling (MWD)
− Perforation markers
• Luminous safety signs (Betalites)
• Smoke detection
• Pipeline operations
− Pig tracking
• Platform structural surveys
− Flooded member detection
Unsealed Sources
• Reservoir operations
− Waterflood investigations
− Sand fraccing
− Gravel packing
• Process investigations
− Flow measurement
− Leak detection
− Residence times
xii November 2001 Issue 1

Unsealed Radioactive Material

• Naturally occurring radioisotopes
− Scales
− Sludges
− Gases
− Waxes
Statutory/Company Appointments
The procedures contained in this document require designated persons to fill certain roles,
some of which are required by statute.
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The following paragraphs are intended to identify the persons, within the Company, responsible
for the use of radioactive materials.
Each Business Unit (BU) shall ensure that individuals are appointed to these positions and their
names should be clearly stated in local rules.
Installation Manager/Site Manager

The Installation Manager/Site Manager has the responsibility for all operations within their
Installation, even though many activities concerning these are delegated to others. This applies
to offshore Installations where the Offshore Installation Manager (OIM), in addition to Company
responsibilities, has statutory responsibilities for all activities associated with the Installation.
The OIM/Site Manager has responsibility for ensuring that in all work with ionising radiation the
following are addressed:
• The appointment of suitably trained personnel to the position of Radiation Protection
Supervisor (RPS)
• All work involving ionising radiation is carried out in accordance with the local rules
• Identification of specific training needs of personnel and arranging attendance at
such training
• In any work with Low Specific Activity (LSA) material/Naturally Occurring Radioactive
Material (NORM):
− Contractor’s employees are fully informed by their employer as to the nature of any work
involving LSA material/NORM
− Obtaining such information from employers, as is necessary, to control the exposure of
their employees
− Informing employees and employers of exposures received in BP controlled areas
− Identifying plant containing LSA material/NORM
November 2001 Issue 1 xiii

Federal Health, Safety and Environment (HSE) Delivery Team

The Federal HSE Delivery Team, on behalf of the Business Unit Leader (BUL), has the overall
responsibility for providing a service to BUs handling radioactive material with respect to:
• Provision of advice on such operations, particularly radiological protection of personnel
• Provision of suitable procedures
• Provision of training courses, for appropriate staff, in the application of the above procedures
• Liaison with the regulatory bodies, namely The Scottish Office Environment Department
through the Scottish Environment Protection Agency, the Department of the Environment
through the Environment Agency, and the Health and Safety Executive
• Arrangement for the services of the Company’s Radiation Protection Adviser
The provision of the services to BUs handling radioactive material will be championed by a
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representative nominated from the Federal HSE Delivery Team with support from the Central
Environment Team and the Upstream Technology Group (UTG).
The appointments of Radiation Protection Adviser (RPA) and RPS are required under
Regulations 13 and 17 of the Ionising Radiation Regulations 1999 respectively.
Radiation Protection Adviser

The RPA must be appointed, in writing, by the Company for the purpose of advising the
employer on observance of the Ionising Radiations Regulations 1999 (IRR99), associated codes
of practice and other regulations pertaining to working with ionising radiations.
The RPA should be consulted in the following matters:
• Restriction of exposure
• Maintenance of engineering controls and other equipment provided for such control
• Identification of controlled and supervised areas
• Control of access to designated areas
• Dosimetry and monitoring
• Drawing up suitable written arrangements and local rules
• Selection of Radiation Protection Supervisors
• Investigation of abnormally high exposures and overexposures
• Training
• Hazard assessment and contingency arrangements
• Prior examination of any plans for new plant or new premises, or modifications to existing
plant or premises from a radiation protection aspect
• Any other aspects of radiation protection that apply to work with ionising radiations carried
out by the employer
• Selection and calibration
xiv November 2001 Issue 1

Radiation Protection Supervisor

Radiation Protection Supervisors are appointed to exercise supervision. They must ensure that
any work with ionising radiation is done in accordance with the local rules. The RPS should also
ensure that any work with radioactive materials, carried out by contractors, is in full compliance
with the requirements of their local rules.
RPSs shall receive appropriate training, including a written assessment, at a BP approved
course prior to appointment. There is no statutory period for refresher training but it is
recommended by the Health and Safety Executive that for those whose work involves
reasonably frequent involvement with operations involving ionising radiation, such as Installation
Fire and Safety Officers or offshore Safety Advisers, the period should be 4 to 5 years.
For those with less frequent involvement, it is considered that 3-yearly refresher training would
be appropriate.
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The Company will appoint each RPS, in writing, and describe the individual’s area of
responsibility, ie for sealed sources only, for sealed and unsealed sources and/or X-ray
generators. The letter of appointment shall be countersigned by the appointed RPS.
The names of all Installation or field RPSs shall be included in the local rules, as required by
Regulation 17 of the Ionising Radiations Regulations 1999 (IRR99).
Nominated Person – Company Appointment

The Nominated Person (NP), a procedural rather than legislative appointment, may be appointed
by Business Units to carry out certain administrative tasks as required by Part 2. These are
primarily the control of equipment contaminated with LSA material once it is sent to an onshore
cleaning facility, and the maintenance of the statutory records as required by an Installation’s
disposal authorisation.
The NP may also be involved (in conjunction with the RPA) in the onshore disposal of bulk LSA
material by whatever route selected.
Review and Update

This document will be subject to 12-monthly review and update, when document holders will
have the opportunity to express opinions and suggest improvements.
However, the document control system allows for continuous update of this document.
As such, any user may at any time identify an error or suggest an improvement using an
Amendment Proposal proforma which is available electronically on the UKCS SMS website,
from the Data Control Centre (DCC) Supervisor or from the Technical Authority.
All holders of this document are registered so that they can be sent updates and be kept
informed of changes or reviews.
November 2001 Issue 1 xv

Responsibility of Copyholders
It is the responsibility of the registered copyholder of controlled hard copy versions to maintain
the accuracy of the document by ensuring that all updates are promptly incorporated and
acknowledged.
Furthermore, the registered copyholder of controlled hard copy versions must at all times
maintain custody of this document unless prior approval is given by the relevant
Technical Authority.
The roles and responsibilities of copyholders and ‘virtual’ copyholders are detailed in Section 1
of the Document Control Procedure (UKCS-DCM-001).
Uncontrolled
xvi November 2001 Issue 1

List of Abbreviations
ALARA As Low As Reasonably Achievable

ALARP As Low As Reasonably Practicable
ATD Analysis, Transport and Disposal
BOP Blowout Preventer
BU Business Unit
BUL Business Unit Leader
DCC Data Control Centre
EA Environment Agency
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ETA Estimated Time of Arrival

ETD Estimated Time of Departure
HSE Health, Safety and Environment
IAEA International Atomic Energy Agency
IATA International Air Transport Association
ICRP International Commission on Radiological Protection
IMDG International Maritime Dangerous Goods
IRR Ionising Radiation Regulations
LSA Low Specific Activity
LWD Logging Whilst Drilling
MWD Measurement While Drilling
NDT Non-destructive Testing
NNS Northern North Sea
NORM Naturally Occurring Radioactive Material
NOS Not Otherwise Specified
NP Nominated Person
OIM Offshore Installation Manager
PPE Personal Protective Equipment
PTW Permit to Work
PU Performance Unit
RIDDOR Reporting of Injuries, Diseases and Dangerous Occurrences Regulations
RPA Radiation Protection Adviser
RPS Radiation Protection Supervisor
RSA Radioactive Substances Act
SEPA Scottish Environment Protection Agency
SNS Southern North Sea
SOR Serious Occurrence Report
March 2002 Issue 1/AM01 xvii

List of Abbreviations (cont’d)
TI Transport Index
TLD Thermoluminescent Dosimeter
UKOOA United Kingdom Offshore Operators Association
UN United Nations
UTG Upstream Technology Group
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xviii March 2002 Issue 1/AM01

Part 1
Sealed Sources, Radiation Generators and
Section 1 Sealed Sources
Section 2 Unsealed Radioactive Material (Radiotracers)

Section 3 Transport of Sealed Sources and Unsealed
Radioactive Materials
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Section 4 Local Rules

Section 5 Documentation
Part 1
November 2001 Issue 1 i/ii
Section 1
Sealed Sources
Paragraph Page
1 Introduction 1-1
2 Description of Sealed Sources 1-1
3 Statutory Testing 1-1

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4 Registrations and Authorisations 1-2
5 Notifications 1-3
6 Storage of Radioactive Materials 1-3
7 Accounting for Sealed Sources 1-3
8 Routine Physical Checks 1-4
9 Radiation Monitors 1-5
10 Radiation Monitoring 1-5
11 Controlled and Supervised Radiation Areas 1-5

11.1 Controlled Area 1-5
11.2 Supervised Area 1-6
12 Prevention of Accidental Exposure 1-7

12.1 Vessel Entry 1-7
12.2 Vessel Low Level 1-8
12.3 Source Holder Removal 1-8
13 Contingency Plan 1-8

13.1 Accidents and Emergency 1-8
13.2 Damage or Suspected Damage to Source 1-9
14 Contractors Using Radioactive

Materials on BP Premises 1-10
Part 1 Sealed Sources

November 2001 Issue 1 1-i/ii
1 Introduction
The use of sealed radioactive sources as process investigation measurement, as control
tools in detectors and quality assessment equipment, as in radiography, is widespread
and increasing.
These local rules, required by Regulation 17 of the Ionising Radiations Regulations 1999
and Section 2 of the Health and Safety at Work etc Act 1974, will ensure that sealed
radioactive sources are used safely and in accordance with the above, and other,
relevant legislation.
2 Description of Sealed Sources

Uncontrolled
The radioactive material used in this type of source is contained in a stainless steel
capsule (approximately 1cm3) and substantially shielded by a heavy lead or steel housing.
Sealed sources may be permanently installed as in the case of density, level and
interface nucleonic measurement instruments and smoke detectors, or mobile as in
radiography sources or portable level gauges.
In all cases, the varying absorption of the emitted radiation by the medium or item under
investigation and the subsequent detection of the attenuated radiation provides the basis
of the measurement techniques.
Within nucleonic instrumentation, the type and size (activity) of the source is determined
by a number of process parameters, with the end view of minimising the amount of
emitted radiation to that necessary for the successful operation of the detection system.
However, within mobile sources used for radiographic examination the activity of the
source is significantly greater than for nucleonic instrumentation to permit the detection
of the incident radiation by the photographic film used, within a reasonable exposure
timescale.
Under circumstances of limited space on offshore Installations, it may be necessary to
limit the source activity, thereby reducing the size of the work area affected during
exposure of the source. Specific permission then has to be sought to increase the
maximum source activity in the event of a particular job requirement.
3 Statutory Testing
Where appropriate, all sealed sources must be tested for leakage at least once in every
24-month period (refer to Section 5 Paragraph 8).
This requirement does not apply to sources that are replaced within the 24-month period
because of decay (eg iridium 192 sources with a 74-day half-life). However, if the source
container is also the transport container, there is a requirement, under the Road
Transport Regulations, to test the container at regular intervals.

November 2001 Issue 1 1-1
Leakage test sampling shall be carried out by a specialist contractor or by the Installation
Radiation Protection Supervisor (RPS) under the supervision of the Radiation Protection
Adviser (RPA) using a prepared procedure. An approved laboratory shall carry out the
analysis of the resultant test swabs.
4 Registrations and Authorisations

The Radioactive Substances Act 1993 (RSA93) requires that anyone wishing to keep or
use radioactive materials must be registered to do so.
The registration shall be obtained, with the assistance of the RPA, from the Scottish
Environment Protection Agency (SEPA), if in Scotland, and from the Environment
Agency (EA) if in England.
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Note: These certificates may take 6 to 8 weeks to process.
If additional sources are to be kept or used on any BP premises, then a registration
permitting these sources to be kept/used must be obtained prior to the sources
being received.
If the registration is to be arranged by a contractor supplying an instrument, the RPA
should be made aware that a new source(s) is to be installed and shall ensure that the
relevant documents have been obtained prior to installation. Sources should not be
accepted onsite, unless a registration certificate covering these sources has been issued
by the appropriate department and the commencement date of the certificate
has passed.
If any radioactive source is no longer required, it may be considered as radioactive waste
by the regulatory body. Unless the Company has an authorisation to accumulate waste,
it may be open to prosecution. Advice shall be sought from the RPA on potential
disposal routes.
Registration and authorisation certificates, issued under Sections 7, 13 and 14 of the
Radioactive Substances Act 1993, must be displayed on the Installation to which
they refer.
If a radioactive source(s) is to be used on more than one Installation, then it is likely that
a ‘mobile’ registration issued under Section 10 of the Radioactive Substances Act 1993
shall be required. A copy of such a registration shall be displayed at each place of work.
Advice on this requirement must be obtained from the RPA.
A source must not be used on premises/sites other than that to which the registration
relates unless a current Section 10 registration is available for the source.
All conditions included in registrations and authorisations must be strictly complied with.
Sealed Sources Part 1

1-2 November 2001 Issue 1
5 Notifications
If radioactive materials are to be used on an Installation for the first time, or there is to
be a significant change in their use, the RPA is to be informed in advance. This will allow
the RPA to decide on the requirement to inform the Health and Safety Executive.
6 Storage of Radioactive Materials

Unless permanently installed as part of a measuring device, eg level or density gauge,
all sources must be kept in a locked store kept solely for radioactive materials,
their immediate containers and associated items such as handling tools. A sign must be
displayed outside the store (preferably on the door) to warn persons in the vicinity that
the store may contain radioactive materials. The sign must include a trefoil and the word
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‘Radioactive’.
The dose rate on the surface of the store should not exceed 7.5 microsievert per hour
(µSvh-1) and preferably be less than 2.5µSvh-1.
If the dose rate exceeds 2.5µSvh-1, consideration shall be given to the designation of the
area as a supervised or controlled area (refer to Paragraph 11).
On offshore Installations, the radioactive materials store, where possible, shall be
situated away from accommodation and office areas. Following advice from SEPA,
the store should not, if possible, be located on an operational jettison platform. Should it
be jettisoned, SEPA may ask for the store to be recovered.
Where space constraints allow, it is preferable that a radioactive materials store shall not
be situated near an explosives store. However, it is appreciated that in offshore
situations, pressure on available space may not permit this.
7 Accounting for Sealed Sources

The BP source accounting procedure is designed to ensure that the whereabouts of
radioactive sources are known and any losses are quickly identified.
The records include the following details for each source:
• Isotope
• Source identification/serial number
• Date of receipt on Installation
• Activity at a specified date
• Whereabouts of the source updated at specified intervals
• The date and destination if removed from the Installation or the date of disposal
(where appropriate)
The above details are included in the ‘Radioactive Source Register Card’ (refer to
Section 5 Paragraph 9).

The frequency at which location updates shall be carried out is as follows:

• Installed gauges – monthly
• Portable gauges – daily
• If portable sources remain in storage for a period of time a weekly check is adequate
The RPS shall confirm that the source is present by carrying out a visual inspection of
the gauge housing backed up, where possible, by radiation monitoring. A check should
also be made to ensure that the gauging system is functioning normally.
Where maintenance operations require the removal of a source within its housing,
this shall only be done under the supervision of the RPS, who shall amend the
Radioactive Source Register Card with the new location of the source. When reinstalled,
the source register shall be updated.
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Source movement records shall be kept on the Installation to which they relate for the
period the source is in use and then for 2 years after the source has been removed
from the Installation. This should be confirmed with SEPA/EA for each Installation,
as the certificates of registration do not specify a time limit.
In the absence of the contractor’s RPS, and after mutual agreement, confirmed in
writing, the BP RPS shall assume responsibility for contractor’s sources left on the
Installation, eg radiography sources, and shall complete the source location checks,
as described in the daily record card (weekly if in storage), on behalf of the
source owners.
If it is suspected that a radioactive source, however small, is lost, the Offshore
Installation Manager (OIM)/Installation/Site Manager must be informed. The RPA and,
if applicable, the Nominated Person (NP) must also be contacted as soon as possible.
The contingency plan for such an incident shall be implemented immediately.
An example of a source record card is given in Section 5.
The RPA (Synetix) will keep on file an up-to-date list of the sources held on each
Installation. To assist with this, the Installation RPS will furnish the RPA with the details
of any new sources installed on the Installation.
8 Routine Physical Checks

Quarterly checks shall be carried out to ensure that the conditions, which may
affect radiological safety, are at the required standard. For installed sources,
these shall include:
• A check on the overall condition, and mounting, of the gauge housing
• A check that the housing is correctly labelled with a trefoil symbol
• A check that the source is secured in the shielded container with a padlock
• A check to ensure that the shutter mechanism has not been locked in the
‘open’ position

9 Radiation Monitors
Calibrated radiation dose rate monitors, appropriate to the radiation being used, must be
available wherever radioactive sources are used. Only trained personnel should carry out
radiation monitoring.
A qualified person must test radiation monitors every 12 months. This examination shall
be arranged through the RPA.
The resultant test certificate must be retained for a minimum of 2 years from the date of
the test.
If a radiation monitor is damaged, such that the accuracy of the calibration may have
been affected, then the instrument must be returned to the RPA who will arrange for the
instrument to be repaired and recalibrated.
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10 Radiation Monitoring
Under normal operating conditions, dose rates on Installations, which incorporate a
sealed radioactive source (nucleonics), shall be monitored quarterly, or following any
work which has been carried out which could affect the adequacy of the shielding.
The results of such monitoring shall be recorded by the RPS and retained on the
Installation for 2 years.
11 Controlled and Supervised Radiation Areas

11.1 Controlled Area
For normal operation, an area must be designated a controlled area if, following a risk
assessment:
• Doses of ionising radiations are likely to lead to an exposed person exceeding 3/10 of
any dose limit for employees aged 18 years or over.
Whole body limit: 20mSv per year
Controlled area: 6mSv per year
Single organ limit (extremities): 500mSv per year
Controlled area: 150mSv per year
Generally, where sealed sources are used on BP Installations, this can be identified as
areas where whole body dose rates exceed 7.5µSvh-1 or extremity dose rates exceed
75µSvh-1. Such areas will typically be:
- Specified areas during radiography
- Inside of process vessels, where nucleonics are installed and the shutter
mechanism is open
- Around radiography source storage area

- Specified areas during well operations involving sealed sources

- Specified areas during use of unsealed radiotracers
In all cases, designation of a controlled area must be supported by risk assessment
and radiation measurement. The assessment will be Platform specific.
For tasks, such as withdrawing a source into the container, which could result in a
dose rate greater than 7.5µSvh-1 for a very short period of time, a suitable written
arrangement is adopted. No such arrangement will be used without consultation and
agreement from the RPA
or
• Should control measures be put in place to ensure persons do not receive a
significant dose of radiation, ie greater than 1mSv per year. Examples of control
measures would be the wearing of Personal Protective Equipment (PPE) or the act of
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closing a shutter mechanism
Controlled areas must be physically barriered off and notices warning of the presence of
a controlled area placed at the barrier. These signs should display:
• The trefoil symbol
• The legend ‘Controlled Area’
• The nature of the radiation, ie gamma radiation
• The type of hazard, eg external hazard
Entry must be restricted to:
• Classified workers
• Workers working under a ‘Suitable Written Arrangement’ agreed with the RPA
Access must be restricted by suitable means and such areas shall be clearly identified in
these local rules.
For <enter name of Installation/Platform> THE FOLLOWING AREAS HAVE BEEN
DESIGNATED CONTROLLED AREAS
11.2 Supervised Area

Areas where, following a risk assessment, radiation doses are likely to exceed the
following supervised area limits, must be designated accordingly:
Whole body limit: 20mSv per year
Supervised area: 1mSv per year
Extremity limit: 500mSv per year
Supervised area: 50mSv per year
In general, for whole body radiation dose rates in excess of 2.5µSvh-1 or extremity dose
rates in excess of 25µSvh-1, a supervised area will be designated.

Typical supervised areas will be within a given distance of a controlled area (unless the
controlled area encompasses the supervised area), eg:
• In the vicinity of a radiography source store
• Specified areas around well services operations involving radioactive sources
• Specified areas around radiography operations
• Specified areas around radiotracer operations
Note: Designation of a supervised area must be supported by a risk assessment and
radiation monitoring. Each assessment will be Platform specific.
Areas designated as supervised areas, because of the presence of sealed radioactive
sources must be recorded in the local rules.
For <enter name of Installation/Platform> THE FOLLOWING AREAS HAVE BEEN
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DESIGNATED SUPERVISED AREAS
12 Prevention of Accidental Exposure

12.1 Vessel Entry
All vessels containing, or having associated with them, a radioactive source shall have a
warning notice displaying the following information on each man entry point:
• A trefoil symbol
• The nature of the hazard, ie gamma radiation
• The type of hazard, eg external hazard (also internal hazard if Low Specific Activity
(LSA) is present)
• Contact RPS should access be required
All sources are to be withdrawn, with the permission of the Area Authority, into their
housing and/or shutters locked in the closed position (confirmed by radiation monitoring,
and the results recorded) before the first manway is opened.
The RPS is responsible for ensuring that this has been done and for reinstatement and
signing the work permit and/or isolation control certificate as appropriate.
The vessel will be designated a controlled area for the first person who enters to
confirm, by measurement, that the shutters have been closed. The area may then,
depending on the presence of LSA material/Naturally Occurring Radioactive Material
(NORM), be de-designated.
An intrinsically safe dose rate meter must be used.

12.2 Vessel Low Level

Installed internal interface sources must be withdrawn into their housings before the
liquid in the vessel falls to a level where the sources are exposed and the potential for
increased vessel external dose rates would exist.
There should be no reason to enter a vessel when a source is exposed unless the
source rod is damaged. Should this be the case, the RPA should be contacted for
further advice.
12.3 Source Holder Removal

As appropriate, sources must be retracted into the source housing. In all cases the
shutter must be locked in the closed position and the key retained by the RPS before the
source holder is removed or any work is carried out which could be affected by the dose
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rates around the vessel concerned.
If a source holder is removed, it shall be confirmed by monitoring that the shutter
is closed.
The padlocked covers must not be removed from the source housings. Sources must
only be removed from their housings by specialist contract staff (eg Synetix staff).
Keys for these padlocks are retained by the RPS. If a source cannot be withdrawn into
its housing or a shutter cannot be closed, the RPS must contact the Company RPA in
the first instance.
It should be noted that to retract certain sources into their housings, one padlock must
be removed. Details as to which source housings are involved and which padlocks
require removal shall be given on an instrument by instrument basis by the
commissioning engineer during installation.
13 Contingency Plan
13.1 Accidents and Emergency
Any damage to the source container which could affect either its operation or the
integrity of the shielding shall be reported immediately to the RPS.
Possible foreseeable accidents include:
• Damage to the source through fire or explosion
• Loss or theft of the source

13.2 Damage or Suspected Damage to Source

This will generally be obviously due to an incident involving the source or source
housing. Should damage be suspected, the following should be implemented.
Note: In the case of fire, no attempt should be made to withdraw sources into their
housings or to close shutters if this involves personnel entering hazardous areas.
After such an emergency, the RPS, with the assistance of the RPA, shall advise
on suitable methods for recovering the sources.
(1) If possible, remove personnel from the area of concern.
(2) Inform the RPS.
(3) Contact the RPA.
(4) Using a radiation dose rate meter, establish the controlled area, ie 7.5µSvh-1.
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(5) If the controlled area demarcation is increased due to the incident, barrier off the
new controlled area.
(6) Assume contamination may be present.
(7) Wear plastic gloves, dustmask and boot covers.
(8) If the source is exposed, the RPS should try to make the source safe.
(a) Use dense material to reduce the dose rate (lead, steel etc).
(b) Using tongs, place the source in lead pot (both may be available from the
radiography company).
(9) If lead pot is not available, shield the source and place it in a secure container.
Barrier off the area. Radiography store may be used.
(10) Using one of the Installation/site contamination monitors (eg EP15/DP2), check the
handling tongs, boot covers, etc for contamination. Should contamination be found
(low level), leave the area barriered off.
(11) The RPS may wish to clean the contaminated area and place the cleaning utensils
and ancillary materials in a sealed plastic bag. Double bag and label
‘Radiation Contamination’. This should be placed in a secure area (radiography
store) until the RPA reaches the site.
(12) Do not use the source until it has been inspected and tested for leakage of
radioactive material.
Note: The radiation dose from point sources (the type used in gauges) reduces on an
inverse square-law basis, ie if the distance to the source is doubled, the dose
rate is reduced by a factor of four.
The dose received is directly proportional to the time spent in the area.

An emergency situation is likely to be an unfamiliar situation. Therefore, if remedial work

is likely to involve source manipulation, the work should be practised using
non-radioactive equipment.
In the event of a significant emergency that immediately threatens the lives of
personnel, or the continuing integrity of the Installation, the potential presence of
radioactive sources should not be regarded as sufficient reason to prevent entry by
rescue teams to any affected area.
13.3 Loss of a Source

In the event that a sealed source is lost, or otherwise unaccounted for, the Installation
RPS shall immediately notify the Installation Manager and Company RPA. In conjunction
with advice from the RPA, the RPS shall initiate a search of all likely areas using available
dose rate meters. When the source is found, the RPS shall implement a retrieval plan
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incorporating Steps (4) to (12) above and information and advice from the RPA.
Note: If the source is not found within 1 hour, the RPS must contact the RPA.
Should a further search for the source prove fruitless, the RPA will advise the Installation
to contact SEPA and the Police to inform them of the missing source. Do not contact
either before discussing the matter with the RPA.
The regulations state that ‘where appropriate’ contingency arrangements will
be practised. This can be done as a paper exercise. Radiography companies and
others using, or handling radioactive sources, should practise their contingency
arrangements annually.
14 Contractors Using Radioactive Materials on

BP Premises
Before work involving contractors using radioactive sources is allowed to commence,
the contractor must have available onsite the following:
(1) A valid certificate of registration for the source(s) being used.
(2) Suitable radiation monitors, complete with valid test certificates.
Note: Neutron monitors will only require to be supplied if neutron sources are
being transferred, from storage containers to instruments or tools, on the
Installation.
For logging sources incorporating neutron radiations or neutron generators,
a neutron monitor should be supplied.
For sources such as small americium/berillium, used in hydrotectors,
a neutron monitor will not be required.
(3) Barriers, warning notices, etc to demarcate controlled or supervised areas.

(4) In the case of Radiographers, an ‘emergency kit’ comprising, as a minimum,

remote handling equipment, bags of lead shot and/or lead sheet of sufficient
thickness and a spare source container, as recommended by the Health and Safety
Executive. The contractor’s local rules will state the contents of the kit.
(5) An RPS onsite to receive the source, unless previously agreed otherwise with the
Installation/Site Manager/RPS.
New contractors shall supply a copy of their local rules, which relate to the work being
carried out, to the Installation RPS for comment before a contract is awarded. Where
existing contractors have revised their local rules, a copy shall be supplied to the
Installation RPS for review. Where considered appropriate, the RPS will liaise with the
RPA over any particular aspects of the rules.
Details relating to the source(s) must be supplied to the Installation Manager, RPS and
the sponsoring department representative, prior to despatch to the Installation.
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These shall include:

• Isotope name
• Source strength at a particular date
• Source identification number
• Container number
• Transport index
• Transport category
• Name of RPS (if known)
Appropriate transport details, eg date, Estimated Time of Departure (ETD),
Estimated Time of Arrival (ETA) and contractor shall be included. Where shipment
through a port is necessary, the Harbour Master must be notified 24 hours prior to
receipt at the port.
Sources must not be left on BP premises unless prior agreement has been agreed
in writing with the Installation/Site Manager.
Note: The use of the contractor checklist included as Section 5 Paragraph 2 will assist
in ensuring that contractors comply with these procedures. In conjunction with a
current copy of their local rules, it will allow the Installation RPS to carry out a
safety audit on the contractor, while the work is in progress.
The Installation RPS should carry out, on occasions, radiation dose rate
monitoring at any barriers set by contractors to confirm the barriers are set at the
correct distance. Similar measurements should be made around contractor’s
transport containers to confirm they are correctly labelled.

November 2001 Issue 1 1-11/12
Section 2
Paragraph Page
1 Introduction 2-1
2 Planning 2-1
3 Registrations and Authorisations 2-3

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4 Notifications 2-3
5 Local Rules 2-3
6 Storage of Unsealed Radioactive Materials 2-4
7 Accounting for Unsealed Radioactive Material 2-4
8 Radiation Monitoring 2-4
9 Controlled and Supervised Radiation Areas 2-5

9.1 Controlled Areas 2-5
9.2 Supervised Areas 2-5
11 Contractors Using Unsealed Radioactive

Material on BP Premises 2-6
Part 1 Unsealed Radioactive Material (Radiotracers)

1 Introduction
It is preferable to use radioactive materials in a sealed form, but this is not always
possible. Radioactive materials are increasingly used to study process performance and,
to do this effectively, the material being studied is labelled with small amounts of a
radioactive isotope of the same element. If there is no suitable radioactive isotope of the
same element, a radioactive isotope of a different, but chemically very similar element,
can be used. Sampling or monitoring can then assess the process performance.
In this type of application, the radioactive material, either solid, liquid or gas, is likely to
be in an unsealed form.
2 Planning
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The use of unsealed radioactive materials presents problems of possible internal

exposure, through absorption, ingestion and inhalation, in addition to that of radiation
dose exposure. For these reasons, planning is particularly important and the Radiation
Protection Adviser (RPA) should be consulted at each stage, including a risk assessment
at the start of the process.
The expertise required and specialised techniques involved, in using unsealed
radioactive materials are such that this type of work is invariably carried out by a
contract company.
The following points will be considered in the risk assessments for radioactive materials:
• The nature of the sources of ionising radiation to be used, or likely to be present,
including accumulation of radon in the working environment
• Estimated radiation dose rates to which anyone can be exposed
• The likelihood of contamination arising and being spread
• The results of any previous personal dosimetry or area monitoring relevant to the
proposed work
• Advice from the manufacturer or supplier of equipment about its safe use
and maintenance
• Engineering control measures and design features already in place or planned
• Any planned systems of work
• Estimated levels of airborne and surface contamination likely to be encountered
• The effectiveness and suitability of Personal Protective Equipment (PPE) to
be provided
• The extent of unrestricted access to working areas where dose rates or
contamination levels are likely to be significant
• Possible accident situations, their likelihood and potential severity

• The consequences of possible failures of control measures – such as electrical

interlocks, ventilation systems and warning devices – or systems of work
• Steps to prevent identified accident situations, or limit their consequences
This prior risk assessment should enable the employer to determine:
(1) What action is needed to ensure that the radiation exposure of all persons is kept
As Low As Reasonably Practicable (ALARP) (Regulation 8(1)).
(2) What steps are necessary to achieve this control of exposure by the use
of engineering controls, design features, safety and warning devices
(Regulation 8(2)(a)) and, in addition, by the development of systems of work
(Regulation 8(2)(b)).
(3) Whether it is appropriate to provide PPE and, if so, what type would be adequate
and suitable (Regulation 8(2)(c)).
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(4) Whether it is appropriate to establish any dose constraints for planning or design
purposes and, if so, what values should be used (Regulation 8(3)).
(5) The need to alter the working conditions of any female employee who declares
she is pregnant or is breastfeeding (Regulation 8(5)).
(6) An appropriate investigation level to check that exposures are being restricted as
far as reasonably practicable (Regulation 8(7)).
(7) What maintenance and testing schedules are required for the control measures
selected (Regulation 10).
(8) What contingency plans are necessary to address reasonably foreseeable
accidents (Regulation 12).
(9) The training needs of classified and non-classified employees (Regulation 14).
(10) The need to designate specific areas as controlled or supervised areas and to
specify local rules (Regulations 16 and 17).
(11) The actions needed to ensure restriction of access and other specific measures in
controlled or supervised areas (Regulation 18).
(12) The need to designate certain employees as classified persons (Regulation 20).
(13) The content of a suitable programme of dose assessment for employees
designated as classified persons and for others who enter controlled areas
(Regulations 18 and 21).
(14) The responsibilities of managers for ensuring compliance with these regulations.
(15) An appropriate programme of monitoring or auditing of arrangements to check that
the requirements of these regulations are being met.
Unsealed Radioactive Material (Radiotracers) Part 1

3 Registrations and Authorisations

The contractor will normally possess the necessary Radioactive Substances Act 1993
(RSA93) registration for this type of work. However, the Installation Radiation Protection
Supervisor (RPS) shall ensure that valid certificates of registration (for the contractor)
and authorisation (for the Installation) are onsite before work commences.
Where discharge of radioactive material to the environment will occur as a result of
the work, the Installation shall require an authorisation for disposal from the Scottish
Environment Protection Agency (SEPA)/Environment Agency (EA). This shall be
progressed by the RPA on request from the sponsoring department.
Registrations/authorisations for this type of work are generally time-limited and therefore
it must be ensured that these certificates are current when the work is carried out.
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Note: As this type of work is dependent on process conditions, delays are not
uncommon and this must be considered in the scheduling of registrations
and authorisations.
4 Notifications
Contract companies carrying out radiotracer work should have notified the Health and
Safety Executive of the type of work they carry out and the likely locations.
The Company should seek assurance that contractors have informed the Health and
Safety Executive.
5 Local Rules
For new work or where new contractors are involved, a copy of relevant sections of their
local rules shall be obtained by the sponsoring group, reviewed by the appropriate RPS
and submitted, if necessary, to the RPA for comment.
Procedures relating to the use of unsealed sources shall be based on the
following criteria:
• Justification
• Optimisation
• Statutory dose limits/constraints
The local rules will be designed to ensure:
• Prevention/limitation of the spread of contamination
• Prevention/limitation of the ingestion/inhalation of radioactive material
• Reduction/limitation of radiation dose

• Correct disposal of radioactive material

• Valid and complete contingency plans are in place for foreseeable incidents
The method of injecting the radioactive material can have a significant effect on the first
and second bullet points above. It is preferable to prepare the radioactive material in a
laboratory environment and bring it to the Installation in a contained system ready for
injection rather than carrying out unnecessary handling and preparation work at the
worksite. This may not always be possible.
6 Storage of Unsealed Radioactive Materials

Unsealed radioactive material will usually be brought onto the Installation immediately
prior to the work being carried out and removed immediately afterwards.
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Storage is addressed by the radioactive material remaining in the transport container,
until it is used, or the remainder transported back to the beach. The container will be
used solely to store the radioactive material and ancillary equipment, eg injection
equipment. The radiation dose rates on the outside of the container will be monitored,
and if greater than 7.5µSvh-1 a controlled area will be designated.
The transport container should be labelled with a trefoil symbol and the legend
‘Radioactive’.
7 Accounting for Unsealed Radioactive Material

Unsealed radioactive materials are generally owned by, and are the responsibility of,
the contractor and therefore the contractor is responsible for the accountancy records.
If unsealed radioactive materials are stored on the Installation without a member of the
contract company being present, then the BP RPS shall assume this responsibility.
This shall have been agreed prior to receipt of the material.
The whereabouts of such material shall be checked and recorded on a daily basis by
the contractor.
8 Radiation Monitoring
Any contractor carrying out work with unsealed radioactive materials must have available
the following monitoring equipment:
• A suitable radiation dose rate monitor
• A suitable contamination monitor
Both monitors shall have been tested within the last 12 months and the contractor’s
RPS shall have valid calibration certificates to hand.

9 Controlled and Supervised Radiation Areas

When unsealed radioactive materials are being used, controlled or supervised areas will
be designated as a result of the prior risk assessment and onsite radiation monitoring.
9.1 Controlled Areas

A controlled area will require to be designated if a prior risk assessment indicates the
effective dose (external plus internal dose) is likely to exceed 6mSv per year.
Should control measures be implemented, to prevent a ‘significant radiation dose’,
ie greater than 1mSv per year, this would require the designation of a controlled area.
The wearing of PPE can be seen by the Health and Safety Executive as a control
measure. PPE will be worn as protection against all possible contaminants and not to
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ensure radiation doses of less than 1mSv/year.

In general, for major unsealed operations, the contractors will automatically designate a
controlled area around the worksite. Each operation will require a prior risk assessment
to be carried out by the contractor, and agreed by the Installation RPS, before controlled
areas are designated.
Only contractors should require access to their own controlled areas. If others require
access, the area should be de-designated, or a suitable written arrangement adopted.
This will be used to confirm the third-party’s radiation dose rate.
Controlled areas will be demarcated and notices displaying the following
information displayed:
• The trefoil symbol
• The legend ‘Radioactive’
• The nature of radiation, ie gamma/beta/alpha
• The nature of the hazard, ie internal/external
9.2 Supervised Areas

A supervised area will require to be designated if a prior risk assessment indicates that
the effective dose (external plus internal dose) is likely to exceed 1mSv per year.
In general, for radiotracer work, no supervised areas will exist outwith controlled areas.
For supervised areas, signs displaying the following information will be displayed:
• A trefoil symbol
• The legend ‘Radioactive’
• The nature of radiation, ie gamma/beta/alpha
• The nature of the hazard, ie internal/external
Eating, drinking, smoking, or any other activities which could encourage the
ingestion/inhalation of radioactive materials, is forbidden in controlled areas where
unsealed radioactive materials are being used.

Washing and changing facilities must be available for anyone leaving supervised or
controlled areas where contamination is likely. These facilities shall be sited so as to
prevent the spread of contamination from the area.
10 Contingency Plan
The contractor’s local rules shall include contingency plans relevant to the type of work
being carried out. This will normally relate to a spillage or uncontrolled release of
radioactive material which could, foreseeably, result in either:
• An employee, or other person, receiving a radiation dose which exceeds any relevant
dose limits or dose constraints
• An area other than an area already designated as a controlled area, which could
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require to be so designated
The quantity of material used in this type of study is generally such that, even during
such an occurrence, due to operators wearing PPE, the possibility of anyone ingesting or
inhaling significant quantities of radioactive material which would result in the person
exceeding a dose limit will be remote.
11 Contractors Using Unsealed Radioactive Material on

BP Premises
The topics detailed in Section 1 Paragraph 14 are also applicable to work with
unsealed material.

Section 3
Transport of Sealed Sources and
Unsealed Radioactive Materials
Paragraph Page
1 Introduction 3-1
2 Sealed Sources 3-1

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3 Shipping Documentation for Radioactive Materials 3-2

3.1 Transport by Air 3-2
3.2 Transport by Sea 3-2
3.3 Transport by Road 3-2
3.4 General 3-2
3.5 Small Quantities of Radioactive Materials 3-3
3.6 Unusual Shipments 3-3
4 Notification of Shipment of Radioactive Materials 3-3
Table
3.1 Surface Dose Rate Limits 3-1
Part 1 Transport of Sealed Sources and Unsealed Radioactive Materials

1 Introduction
In general, the transportation of radioactive materials will be the responsibility of the
contractor using the material. However, if BP transport their own radioactive materials,
the consigning Radiation Protection Supervisor (RPS) will ensure that the following
procedures are implemented.
It must be noted that transport commences the moment that a radioactive substance is
loaded onto a conveyance and ceases only when it is taken off. Transport containers
located on an Installation for a significant period of time are not in transit and the
designation of controlled and/or supervised areas around the container must be
considered, and all the implications which that implies, eg barriers, restricted entry,
warning notices.
During short-term interruptions in transportation, eg awaiting a crane, designation of a
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controlled area may not be necessary, provided the conditions in Regulations 8 and 16 of
lonising Radiations Regulations 1999 are satisfied.
2 Sealed Sources
The transport container will be a Type A container, ie it must have passed the
appropriate tests and be indelibly and legibly labelled as a ‘Type A package’.
The container must carry two appropriately completed transport labels affixed to
opposite sides of the container, ie White – I, Yellow – II, Yellow – III.
The surface dose rate limits for each package are shown in Table 3.1.
Category Surface Dose Rate (µSvh-1) Transport Index

White – I Not more than 5 0
Yellow – II More than 5 but not more than 500 More than 0 but not more than 1
Yellow – III More than 500 but not more More than 1 but not more than 10
than 2000
Table 3.1 Surface Dose Rate Limits
The transport index is calculated from the dose rate at 1 metre in µSvh-1 divided by 10.
The normal limit for transport is a maximum of 50 transport indices per vehicle or
freight container.
Freight containers carrying radioactive material must carry the appropriate transport label
on each of its four sides.

3 Shipping Documentation for Radioactive Materials

3.1 Transport by Air
The carrier must be given two completed copies of the International Air Transport
Association (IATA) ‘Shipper’s Declaration for Dangerous Goods’ form (refer to the IATA
Dangerous Goods Regulations). In addition, special form certificates for the source must
be provided where appropriate.
Note: Excepted packages do not require a dangerous goods form.
3.2 Transport by Sea

The carrier must be supplied with two completed copies of the International Maritime
Dangerous Goods (IMDG) ‘Shipper’s Declaration for Dangerous Goods’ (refer to the
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IMDG Code). In addition, special form certificates must be provided where appropriate.
3.3 Transport by Road

The carrier must be supplied with a valid consignment note, as required under the
Radioactive Material (Road Transport) (Great Britain) Regulations 1996. A special form of
certificate may also be required.
3.4 General
The person who offers dangerous goods (other than excepted packages) for transport
must provide the transport contractor with two copies of the transport document
(Shipper’s Certificate for Radioactive Material) completed and signed. The document
must provide certain information.
The following is a typical example of the information required:
Isotope: Iridium 192

Radioactive substance: Class 7
Schedule Number: 8
Physical form: Solid
United Nations (UN) Number: 2974 Radioactive material, special form,
Not Otherwise Specified (NOS)
Activity of contents (Bq): 10GBq
Package type: Type A
Category: Yellow – III
Transport index: 3
Surface dose rate of package (µSvh-1): 100
Transport of Sealed Sources and Unsealed Radioactive Materials Part 1

If the materials are to be transported by road, then a reference must be made on the
Shipper’s Certificate that the form of packaging conforms to the Radioactive Material
(Road Transport) (Great Britain) Regulations 1996.
3.5 Small Quantities of Radioactive Materials

Small quantities of radioactive materials can be transported as excepted packages.
Typical examples of such materials are ionisation-type smoke detectors, test sources
and Low Specific Activity (LSA) material samples (for the latter refer to Part 2 Section 3
Appendix 3C).
The total activity allowed in a package containing smoke detectors is 200MBq (5.4mCi)
with any individual detector not exceeding 2MBq.
The consignment note which relates to the smoke detectors will be marked
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‘RADIOACTIVE MATERIAL – EXCEPTED PACKAGE, INSTRUMENTS’.

UN number 2910 will be used.
For samples: ‘RADIOACTIVE MATERIAL – EXCEPTED PACKAGE – LIMITED QUANTITY
OF MATERIAL’, UN number 2910 will be used.
External package labelling is not necessary in this case, but advice on the radioactive
content of the package must be apparent when the package is opened.
3.6 Unusual Shipments

If you are unsure about any aspect of transportation, consult the Company Radiation
Protection Adviser (RPA).
4 Notification of Shipment of Radioactive Materials

The following objectives must be met in any transport operation involving the shipment
of radioactive materials:
• The radiation doses received by anyone handling the container must be kept As Low
As Reasonably Achievable (ALARA)
• The source container must be able to withstand the rigours of the journey
• Every effort must be made to ensure that the source is not lost or damaged during
transport operations

To ensure that all relevant personnel are aware of any movement of radioactive
materials, the following details should be faxed to:
(1) The Offshore Installation Manager (OIM)/Site Manager and RPS or Safety Adviser,
supply base, Harbour Master – for shipments to a BP site/Installation;
and
(2) Contractor’s representative, supply base, Harbour Master – for shipments from a
BP site/Installation:
(a) Isotope name.
(b) Number of sources in shipment.
(c) Activity of each source.
(d) Source serial number(s) (if applicable).
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(e) UN number.
(f) Package type.
(g) Category (White I, Yellow II or III).
(h) Transport index.
(i) Dose rate at surface of container.
(j) RPS responsible for source (if applicable).
5 Contingency Plan
Should a source container be found to be damaged on receipt at an Installation, or supply
base, the local RPS must be notified immediately and the container quarantined.
The RPS will then determine whether the damage has affected the integrity of the
shielding within the container. A course of action will be planned, following consultation
with the RPA.
Transport of Sealed Sources and Unsealed Radioactive Materials Part 1

Section 4
Local Rules
Paragraph Page
1 X-ray Mail Examination Cabinet 4-1

1.1 Contingency Arrangements 4-1
2 Ionisation Smoke Detectors 4-2
3 Portable Cylinder Level Indicators 4-3

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4 The Use of Personal Thermoluminescent

Dosimeters (TLDs) 4-4
Part 1 Local Rules

1 X-ray Mail Examination Cabinet

• The cabinet will be suitably marked, using a trefoil symbol, to indicate the presence of
ionising radiations
• No persons shall attempt to put any part of their body into the inspection area when
the X-rays are energised
• No persons shall misuse, modify or deliberately damage the X-ray generator
• The cabinet will only be used by, or under the supervision of, persons authorised in
writing by the Safety Manager or Radiation Protection Supervisor (RPS)
• The door of the cabinet will not be opened when the X-ray tube is energised
• A radiation survey will be carried out at least annually or following any damage,
or repair, which could affect the integrity of the shielding. This survey is to include a
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check on the operation of the interlock switch on the cabinet door

• Records of the results of these surveys are to be kept on the Installation for at least
2 years from the date of the survey
• This survey would normally be carried out by the Radiation Protection Adviser (RPA)
during the annual audit
Name of RPS: <enter name>
Contact number: <enter number>
1.1 Contingency Arrangements

Possible accidents or incidents have been identified as damage to the equipment caused
by electrical failure or accidental damage.
Accidental damage could affect the integrity of the shielding. Should this be obvious,
or suspected, the generator should be disconnected from the mains and not brought
back into service until it has been checked and pronounced fit for use by an authorised
service engineer.
Electrical failure should cause the unit to de-energise. Should the failure cause an
inability to de-energise the unit, the mains supply should be disconnected. Before the
unit is brought back into service, an authorised engineer is to be consulted.
No controlled or supervised areas exist around the outside of the cabinet.
A copy of this page will be posted close to the X-ray generator.
Part 1 Local Rules

2 Ionisation Smoke Detectors

A registration under Section 7 of The Radioactive Substances Act 1993 is required
for the storage of ionisation smoke detectors containing the isotope americium 241,
if the activity content exceeds 40KBq. Below this, detectors are exempt from
registration for storage but the receipt, issue and disposal shall be controlled as
described below.
Note: All installed detectors are exempt from registration. However, damaged
detectors should be returned to the manufacturers or disposed of as soon
as possible as the Installation does not have an authorisation to accumulate
Am 241 waste.
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(1) All smoke detectors on the premises must either be installed in their operational
position or in a designated, secure and correctly labelled (trefoil symbol and legend
‘Radioactive’) store.
(2) Smoke detectors must only be removed from the store, or from an installed
locations, by authorised persons.
(3) A record must be kept to account for the numbers and locations of all smoke
detectors on the premises. The smoke detection installation record, or plans
showing this, is adequate for installed detectors. Detectors in store should be
recorded in a separate register, which includes the following information:
• The number of spare (usable) detectors, and their total activity
• The number of damaged detectors, and their total activity
This record is to be updated following any increase or decrease in the numbers.
(4) The RPS is to audit these records every 3/6 months.
No controlled or supervised areas exist within or outwith the storage area.
A copy of this page will be kept with the spare smoke detectors.
Local Rules Part 1

3 Portable Cylinder Level Indicators

These rules apply to portable cylinder level indicators such as those supplied by Panax,
Ginge or Negretti, which employ sealed sources of caesium 137 not exceeding 26MBq
(700µCi) or cobalt 60 not exceeding 18.5MBq (500µCi).
(1) When not in use, the level indicator must be locked in the transport box supplied
by the manufacturer. Care must be taken to ensure that the gauge is properly
located in the box and the source is inserted into the shield block. The box must be
kept in a secure location, the key to which is held by the RPS or Nominated
Person.
(2) A record must be kept by the RPS to account for the whereabouts of the
radioactive source. The record must be updated every time the equipment is
used or, if in storage, at intervals not exceeding 1 week.
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(3) A classified worker may use the equipment for an unspecified period of time.
However, a limit of 240 hours per year is recommended to ensure that
6mSv per year is not exceeded.
(4) A non-classified worker may only use the equipment, under a suitable written
arrangement, for a maximum time of 40 hours in any working year. A record must
be kept to prove that this time restriction is adhered to.
(5) A test for leakage of the radioactive substance must be carried out on the sealed
source in the equipment at intervals not exceeding 24 months. A record must be
kept of the results of each test for at least 2 years from the date of the test.
The RPA or the RPS will carry out the test.
A controlled area will exist within 1 metre of the gauge, while it is in use. There is
no requirement to delineate the area as constant supervision of the source will
be employed.
No supervised areas will exist outwith the controlled area.
A copy of this page will be kept with the portable level gauge.
Part 1 Local Rules

4 The Use of Personal Thermoluminescent

Dosimeters (TLDs)
TLDs are used to assess the radiation doses received by persons who are involved in
work with ionising radiations and are not just for use by classified workers. The typical
level of detection is 0.1mSv.
These procedures will ensure that this assessment is as accurate as possible.
(1) Dosimeters shall always be used in the holder provided. They should be placed in
the holder such that the user’s name or identification number is clearly visible.
(2) The dosimeter is to be used only by the person to whom it was issued.
(3) The loss of a dosimeter will be reported immediately to the local RPS or the RPA.
The person should refrain from certain work with radioactive materials until a
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replacement TLD is issued.
(4) The dosimeter will be returned to the System Administrator as soon as possible
after a new TLD has been received.
(5) Dosimeters will be attached to the outside of normal work overalls and not placed
in pockets where they could be shielded.
(6) Dosimeters are reasonably robust but will not withstand laundering, crushing, etc.
If it is suspected that a dosimeter has been mishandled or damaged, report and
return it to the local RPS or System Administrator and a replacement will
be issued.
(7) Keep dosimeters away from heat sources and do not leave on radiators for
long periods.
(8) Dosimeters shall be worn when there is any risk of exposure to radiation whilst
at work.
(9) Care shall be taken to prevent exposure of dosimeters when they are not being
worn. They shall not be worn during medical procedures which involve exposure to
ionising radiations if the wearer is the patient, eg X-ray examinations.
Local Rules Part 1

Section 5
Documentation
Paragraph Page
1 Copies of Local Registrations/Authorisations

Under the Radioactive Substances Act 1993
for Sealed or Unsealed Sources 5-1
2 Contractor’s Checklist 5-2

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3 Radiation Protection Supervisors – Appointments 5-4
4 Vessel Entry Warning Notice 5-5
5 Radiation Monitoring Instruments 5-7

5.1 Gamma Dose Rate Monitors 5-7
5.2 Neutron Monitors 5-8
6 Radiation Monitor Statutory Test Certificate (Example) 5-9
7 Sealed Source Statutory Test Certificate (Example) 5-10
8 Procedure for the Statutory Leakage Testing

of Sealed Sources 5-11
8.1 Introduction 5-11
8.2 Equipment Required 5-11
8.3 Method 5-11
9 Radioactive Source Registration Card (Mobile Sources) 5-12
10 BP RPS – Letter of Appointment 5-13
11 Shipper’s Certificate for Radioactive Materials 5-14
12 Radioactive Source Accountancy/Radiation

Monitoring/Safety Checks (Fixed Sources) 5-15
Part 1 Documentation
1 Copies of Local Registrations/Authorisations Under

the Radioactive Substances Act 1993 for Sealed or
Unsealed Sources
Each Installation is to insert copies of all current registrations and authorisations which
relate to the premises except for those which refer to Low Specific Activity (LSA)
material or Naturally Occurring Radioactive Material (NORM).
These shall be included in Part 2 Section 3 Appendix 3D.
Uncontrolled
2 Contractor’s Checklist
Checklist:
Details of Contractor Using Radioactive Materials on BP Installations
Installation: ...................................................................................................................................................
Uncontrolled
Contractor’s name and address: ...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
Contract company’s RPA: .............................................................................. Location:

................................................ ...
Contract company’s site RPS: .............................................................................. Location:
................................................ ...
Nature of work: ...................................................................................................................................................
...................................................................................................................................................
Current registration available for

materials/sources to be used: Yes No
Current authorisation available for

disposal of radioactive waste: Yes No
Certification seen: Yes No
Notification given to HSE: Yes No N/A
Classified workers: Yes No
Dosimetry available: Yes No Ty pe: Film TLD Other
Gamma Radiation Monitor: Yes No N/A Func tioning: Yes No
Test certificate available: Yes No
Contamination Monitor: Yes No N/A Func tioning: Yes No
Neutron Monitor: Yes No N/A Func tioning: Yes No
UKCSSOP004_001.doc
Documentation Part 1
5-2 March 2002 Issue 1/AM01
Source movement (to site) –

details adequate: Yes No
Container/packaging adequate: Yes No
Container/packaging –
adequate labelling: Yes No
Source(s) tested for leakage

within last 24 months: Yes No N/A
Movement record whilst

on Installation: Yes No N/A
Intended source storage

location (if applicable): .....................................................................................................................................
Uncontrolled
Equipment/notices for
controlled areas adequate: Yes No
Contractor’s local rules for

the proposed work: Available: Yes No A dequate: Yes No
Include contingency plans: Yes No
Equipment provided as
required in any contingency
plan, eg handling tongs,
lead shielding etc: Yes No
Polar diagram for neutron/

gamma doses available for
neutron sources: Yes No N/A
Comments:
................................................................................................................................................................................................
................................................................................................................................................................................................
................................................................................................................................................................................................
................................................................................................................................................................................................
................................................................................................................................................................................................
Signed for Signed for

BP (RPS): ........................................................................... Contractor:
................................................... ...........................
Print: ........................................................................... Print:

................................................... ...........................
Date: ........................................................................... Date:

................................................... ...........................
UKCSSOP004_002.doc
March 2002 Issue 1/AM01 5-3
3 Radiation Protection Supervisors – Appointments

Each Installation is to insert the Letters of Appointment of the Radiation Protection
Supervisors (RPSs) appointed for the Installation or appropriate area.
Uncontrolled
4 Vessel Entry Warning Notice
CAUTION
Uncontrolled
RADIATION
(1) No entry to this vessel without clearance

from the Radiation Protection Supervisor (RPS).
(2) Contact the RPS via the control room.
(3) In the event of any unusual occurrence

involving the source of radiation, contact:
................................................................(RPS).
(4) Controlled area: Yes/No.
(5) Type of radiation: Alpha/Beta/Gamma.
(6) Nature of hazard: External/Internal.
UKCSSOP004_003.doc
5 Radiation Monitoring Instruments

5.1 Gamma Dose Rate Monitors
A range of dose rate meters are used by BP. These include the following:
• Nuclear Enterprises IDR1/B
• Wallac RD8
• Gammatrol PRI90
• Gammatrol PRI9
The operation of such instruments shall be in accordance with the manufacturer’s
instructions. Care must be taken in the selection of the appropriate instrument range and
in the interpretation of the reading obtained.
Uncontrolled
The Nuclear Enterprises IDR1/B and the Gammatrol PRI9 and PRI90 are intrinsically safe
monitors, the Wallac RD8 is not intrinsically safe. The intrinsic safety of any other type
of dose rate meter must be checked before use.
All dose rate monitors must have been calibrated by the manufacturer prior to despatch
and at least once during any subsequent 12-month period. A current calibration
certificate shall be available on the Installation for each monitor. The certificate is to be
retained for a minimum of 2 years from the date of test.
When carrying out dose rate measurements, it shall be checked whether a multiplying
factor needs to be applied to any measurement mode. Such factors, where appropriate,
should be printed on the instrument’s current certificate of test.
If a multiplying factor has been specified, the indicated dose rate reading must be
multiplied by the given factor to obtain the true dose rate.
Example:
Indicated dose rate = 7.2µSvh-1 in air
Multiplication factor ‘M’ = 1.25
True dose rate = 7.2 x 1.25 = 9µSvh-1 in air
5.2 Neutron Monitors

Neutron monitors are available for use on certain installations and will usually be one of
two types:
• NE Technology NM2B dose equivalent monitor containing a BF3 proportional counter
within a cylindrical polythene shield.
This is sensitive to neutron radiation in the range 0.025eV (thermal) to 15MeV
• NE Technology MK7 NRM dose equivalent monitor comprising a rate meter made up
of a MK27 NH detector assembly, MK16 NV indicator assembly and a helium 3
proportional counter within a spherical polythene shield.
This is sensitive to neutron radiation in the range 0.025eV to 7MeV. The use of this
monitor in work with a neutron generator which typically emits neutrons of 14MeV
would be for verification of the presence of neutrons only and not for dose
Uncontrolled
measurements
The operation of each monitor shall be in accordance with the manufacturer’s
instructions. Statutory calibration is as for other radiation monitors.
Neither monitor is intrinsically safe.
Both the above monitors have low sensitivity to gamma radiation and in any work where
both gamma and neutron radiation is emitted it is necessary to sum the exposure rate
from both sources for comparison with statutory limits. Care must be exercised when
interpreting the radiation units used by each monitor.
6 Radiation Monitor Statutory Test Certificate

(Example)
RECORD OF TESTS OF RADIATION MONITORING EQUIPMENT
Name and address of employer:
BP,
Farburn Industrial Estate, Dyce, Aberdeen.
Address of premises for which the equipment is provided (if different from above):
Uncontrolled
Description of equipment: Wallac Serial No: 76567
Attached probe (where applicable): Serial No:
Type Result Full Names and Description Signature of Qualified

of of
Date of Person Who Made Person Who Made or
Test Test the Test Supervised the Test
(i) (ii)
Periodic 18/03/94 Calibration A P Graham

Retest satisfactory Commissioning Engineer
Pavilion 11, Belasis
Hall Technology Park,
Billingham.
(i) Indicates whether first test, period retest or retest after repair of a defect which could
affect the accuracy of the equipment.
(ii) For a dose rate monitor, the result of ‘satisfactory‘ indicates an accuracy equal to or
better than ± 10%.
UKCSSOP004_004.ai
7 Sealed Source Statutory Test Certificate (Example)
Tracerco
Unit 4, The Technology Centre, Offshore Technology Park,
Claymore Drive, Bridge of Don, Aberdeen, AB23 8GD
Telephone – Aberdeen (01224) 826628
Facsimile – Aberdeen (01224) 827095
RECORD OF TEST OF SEALED SOURCES FOR

LEAKAGE OF RADIOACTIVE SUBSTANCES
In compliance with the lonising Radiations Regulations 1985.
Name and address of premises where sealed source is normally kept:
Uncontrolled
....................................................................................................................................................
....................................................................................................................................................
....................................................................................................................................................
Source details:
Radioactive substances in the sealed source:
..........................................................................................................
Distinguishing number or identification mark:
..........................................................................................................
Whether the sealed source is permanently installed in a container:
..........................................................................................................
The leakage test carried out on this sealed source was in compliance with the lonising Radiations Regulations 1985
and British Standard BS 5288 1976, Appendix D, Specification for Sealed Radioactive Sources.
Date of Reason for Test Activity Results of Full Name and Address Signature of
Test and Measured Test Pass or of Person Carrying Out Person Carrying
Method Used Fail the Work Out the Test
If the measured activity is less than 185Bq, the sealed source is considered to be leak-free. (185 Becquerels is
equivalent to 5 NanoCuries (nCi).)
Note: Should access to the source be required, greater amounts of contamination may be encountered.
UKCSSOP004_005.doc
8 Procedure for the Statutory Leakage Testing of

Sealed Sources
8.1 Introduction
It is a condition of the Ionising Radiations Regulations 1999 that sealed sources are
tested for leakage at periods not exceeding 24 months, unless this is unrealistic in terms
of the half-life of the radionuclide.
This test may be carried out by the Installation RPS, or by the Radiation Protection
Adviser (RPA) during the annual audit.
This procedure describes the method by which sealed sources installed in nucleonic
gauges are tested for leakage. The procedure listed is in addition to normal work permit
and safety requirements.
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8.2 Equipment Required

• Gamma radiation dosimeter
• Laboratory tongs (or pliers)
• Cotton wool or similar absorbent material
• Water
• Plastic sample bags
• Contamination monitor – Mini Monitor Series 900 (or similar)
8.3 Method
(1) Carry out radiation dose rate measurements around the source housing. If readings
are in excess of 7.5µSv/h contact the Company RPA for further advice before
proceeding.
(2) Moisten a swab of cotton wool with water. Hold the moistened swab in the tongs
and wipe thoroughly all areas that could reasonably be expected to reveal any
leakage of the source. This would include gasket areas where, for example,
the shutter mechanism is inserted into the source housing.
(3) Put the swab in the sample bag, double bag and label with the Installation name,
date, radionuclide, source activity and source serial number.
(4) Monitor the swab package with a Mini Monitor Series 900 for any evidence of
contamination. An increased reading will show this. If so, notify the RPA.
(5) Send the swab and current leakage test certificate, to Synetix Tracerco, Unit 4,
Technology Centre, Claymore Drive, Bridge of Don, Aberdeen for analysis.
(6) Where the test has been done by the RPS, then Tracerco will issue the analysis
report and a blank certificate for completion by the person who carried out the
leak test. If the test was done by the RPA then Tracerco will issue a completed
leak test certificate.
(7) The certificate should be retained on file for 3 years.
9
5-12
Radioactive Source Registration Card
Disting Radioactive Date Nature of Date of Received by
Mark No Strength Measured Element Receipt (Signature)
Documentation
UKCS-SOP-004
Address of normal Date leak test due Initial daily when source
location of source (when completed) checked for location Year
Location Dept/ 1
Wks Division
2
Used for 3
Entry to Primary Location Departure from Primary Location 4

Date and Time Checked by Date and Time Removed by New Location 5
of Entry (Signature) of Departure (Signature) (notify)
6
(Mobile Sources)
10
11
12
13
14
15
16
17
18
19
20
21
Radioactive Source Registration Card
22
23
24
25
26
27
28
29
30
31
March 2002 Issue 1/AM01

Part 1
Working with Radioactive Materials
UKCSSOP004_006.doc
Uncontrolled
10 BP RPS – Letter of Appointment
Notification of Appointment
Under
Ionising Radiations Regulations 1999
Uncontrolled
Regulation 17 of the above legislation requires that where work with ionising
radiations is carried out under local rules, the employer shall appoint a Radiation
Protection Supervisor for the purpose of securing compliance with the
regulations.
(1) To ensure that work with ionising radiations is supervised to the extent
necessary to enable the work to be carried out in accordance with the
requirements of the Ionising Radiations Regulations 1999.
(2) To ensure that all reasonable steps are taken to ensure that any local
rules that are relevant to that work are observed.
For the purposes of these regulations:
Mr/Mrs/Miss:
is appointed Radiation Protection Supervisor for the following areas:
Signed: Position:
Date:
Signed: Radiation Protection Adviser
Date:
Signed: Radiation Protection Supervisor
Date:
Distribution: Original – RPS

Copy 1 – Noticeboards
Copy 2 – Installation Records
UKCSSOP004_007.doc
11 Shipper’s Certificate for Radioactive Materials
SHIPPER’S CERTIFICATE FOR RADIOACTIVE MATERIALS
Uncontrolled
This is to certify that the goods listed below are properly described and are packed and marked in accordance with
the applicable provisions of the appropriate transport requirements.
Description of Material
Isotope
Radioactive Substance
Schedule No
Physical Form
UN Number
Activity of Contents (Bq)
Package Type
Category
Transport Index
Surface Dose Rate of

Package micro Svh-1
Shipper: Shipped by:
Signed: ................................................................................... Date:

........................................... .............................
UKCSSOP004_008.doc
12 Radioactive Source Accountancy/Radiation

Monitoring/Safety Checks (Fixed Sources)
Radioactive Source Accountancy

Safety Checks
Radiation Monitoring
for Fixed Radiation Sources
Uncontrolled
Nature of Source:
Activity of Source:
Serial/Identification Number:
Location:
Date of Receipt:
Date and Manner of Disposal:
Safety Checks:
The following safety checks are carried out on the gauging equipment:
(1) General condition of the gauge and detection system.
(2) Gauge correctly labelled.
(3) Shutter mechanism not padlocked in the open position.
Month/Date Location Safety Faults Dose Rate at Dose Rate at

Checks Source Detector
µSv/h µSv/h
Audit by Installation RPS on:
Signature:
UKCSSOP004_009.doc
Part 2
Low Specific Activity (LSA) and Naturally
Occurring Radioactive Material (NORM)
Section 1 Introduction to LSA and NORM
Section 2 The Ionising Radiation Regulations 1999,

Regulation 18(2) BP Written Arrangement for
Working in a Controlled Area Due to Levels of
LSA Scale
Uncontrolled
Section 3 Local Rules

Section 4 Documentation
Part 2
November 2001 Issue 1 i/ii
Section 1
Introduction to LSA and NORM
Paragraph Page
1 Introduction 1-1
2 Statutory Requirements 1-2
3 Basis for Local Rules 1-2

Uncontrolled
4 General Arrangements for Safe Working 1-3
5 Airborne Contamination 1-4
6 Radiation Passbook 1-5
7 The Radiation Protection Supervisor (RPS) 1-6

7.1 List of RPSs for Installation/Field 1-7
Part 2 Introduction to LSA and NORM

1 Introduction
Many oilfields worldwide are now known to produce solid deposits in the form of scales,
sands and sludges which contain quantities of naturally occurring radioisotopes.
Generally, it is the more mature oilfields that are affected when injected water mixes
with the natural formation water and chemical incompatibility leads to the formation of
these deposits. However, radioactive deposits have also been found where injection
water breakthrough has not occurred. Gamma-ray anomalies, seen to develop on well
production logs, can provide an early indication of the formation of these naturally
radioactive deposits which may form in well tubing, flowlines, process vessels, process
water systems and oil export lines.
The radioactive deposits have, to date, been of Low Specific Activity (LSA) although the
levels and amounts of material differ widely even where breakthrough has occurred.
Uncontrolled
The radioactive isotope components in the deposits originate from naturally occurring
uranium 238 and thorium 232.
In the Northern North Sea (NNS), the radionuclides radium 226 from the
uranium 238 decay chain and radium 228 and radium 224 from the thorium 232 chain
are deposited in conjunction with primarily barium sulphate scales and solids.
These isotopes decay into daughter products with associated emissions of radiation.
In order to reflect this, and to avoid the necessity for calculating limits based on the
mixture of isotopes present at any particular time, the limits used in this document for
the NNS operations are those for radium 226, including the daughter isotopes,
because they are the most restrictive of the isotopes present in the mixture.
Any reference to radium in the document may be taken to infer any combination of
radium 226, radium 228, radium 224 and the majority of their daughter isotopes
in equilibrium.
In the Southern North Sea (SNS) Installations and UK onshore locations, the presence of
barium sulphate-based radioactive scales, as described above, has not been significant.
However, process plant deposits and coatings on equipment have been identified as
containing significant quantities of lead 210, its daughter bismuth 210 and polonium 210
which are also part of the uranium 238 decay chain. Considerable research work has
been undertaken to reach an understanding of the mechanisms involved in this particular
aspect of the problem of occurring natural activity and in the prevention of
its occurrence.
The basic criteria of the system of control will, however, remain unchanged whatever
isotope mixture is identified.
Note: Separate local rules and a system of work have been prepared for
BP Installations affected in this way and are not included in this document.

2 Statutory Requirements
The disposal of all radioactive material, as waste, is controlled by law through a system
of authorisations. These authorisations define the nature and activity of radioactive
material that can be disposed of and the method of disposal.
In Scotland and the NNS waters, this is carried out by the Scottish Environment
Protection Agency (SEPA), who issue authorisations under the 1993 Radioactive
Substances Act for the accumulation and disposal of radioactive waste.
This Installation-specific document specifies the conditions under which Naturally
Occurring Radioactive Material (NORM) may be accumulated and disposed of and should
be read and followed closely. Authorisation is also given to send contaminated
equipment to specialist cleaning contractors when effective cleaning cannot be carried
out onsite.
Uncontrolled
In England, the Environment Agency (EA) carries out an identical role. However, there
remains a significant difference in the interpretation of what is waste by the two
authorities with an effect on the statutory administration of the problem from a licensing
point of view. Advice on this matter should be sought from the Radiation Protection
Adviser (RPA).
Note: A copy of the authorisation must be displayed on the Installation.
Routine radiochemical analysis of the material is required to:
• Identify the radioactive components
• Obtain the isotopic specific activity of the material to enable determination of the
elemental activity in terms of Becquerels per gram (Bq/g-1). In conjunction with
estimates of the weight of material, this allows comparison against legislative limits
and the calculation of the total activity content of the material in question
3 Basis for Local Rules

Radium 226, radium 228, radium 224 and their daughters emit alpha (α) and beta (β)
particles and gamma (γ) radiation. Lead 210 and polonium 210 emit β and α particles
respectively and gamma radiation of significantly lesser energy than the radium isotopes.
The specific activity of the deposits is such that the external radiation from inside closed
plant, particularly in southern locations, is low. However, when plant is opened for
cleaning or maintenance, the material is encountered and may be released and the
potential for personal and area contamination increases.
Strict precautions are necessary to avoid:
• Contamination of worker’s skin and clothing and the unnecessary spread of
contamination
• Generating airborne particles, which would increase the possibility of ingestion or
inhalation of radioactive material
Introduction to LSA and NORM Part 2

The local rules in this manual describe work procedures designed to:
• Contain the contamination as near as possible to its site of production
• Limit the possibility of ingestion or inhalation
• Control/restrict direct radiation exposure of workers
• Ensure that any contaminated items are cleaned, transported and disposed of safely
in accordance with statutory requirements
• Ensure that the disposal of bulk waste is in accordance with statutory requirements
Local rules for specific operations on particular Installations have been prepared and
used for many years. These are included within the manual for these Installations as part
of Section 3.
Examples of such local rules include:
Uncontrolled
• The control of LSA material from pigging operations

• The control of LSA material from well mill-out operations
These local rules have been drawn up to meet BP’s responsibilities under the Health and
Safety at Work etc Act 1974, The Management of Health and Safety at Work
Regulations 1992, The Radioactive Substances Act 1993 and the Ionising Radiations
Regulations 1999.
4 General Arrangements for Safe Working

Each Installation/site should clearly identify plant known to be affected or suspected of
being affected by LSA/NORM. Work permits will ensure that the plant is opened only in
accordance with simple precautions described in the local rules. Radiation measuring
instruments shall be used to determine if radioactive deposits are present.
Situations may arise where a build-up of LSA scale, on the inside of vessels, results in
radiation dose rates significantly above background. In such instances, radiation dose
rate monitoring will determine the requirement for controlled or supervised areas.
It is necessary if such situations arise to:
• Keep a record of all long-term supervised and controlled areas
• Carry out and record regular measurements to determine if the area designation
needs to be changed
• Ensure that controlled areas are physically demarcated, correctly signed and entry
restricted to classified persons or persons operating under a suitable written
arrangement. Demarcation should be appropriate for the type of work to be
carried out
• Ensure that subsequent operations in these areas are carried out in accordance with
the appropriate local rules

There is requirement in the Ionising Radiations Regulations 1999 to display appropriate

signs around a supervised area and to show, through risk assessment, that radiation
doses will not exceed 6mSv/year. It may be operationally advantageous to include the
supervised area within the controlled area.
It is important to note that items of equipment which may be contaminated, at a level
which does not require special precautions when working, may contain scale of a
specific activity sufficient to require the items to be disposed of in a controlled manner.
The requirements detailed in Section 3 must therefore be implemented in addition to the
appropriate local rules and system of work.
The local rules produced for the different work activities will be suitable for application in
both supervised and controlled areas. In addition, workers employed in controlled
areas shall either be classified workers or non-classified workers who work to the
suitable written arrangement. The BP system of work (refer to Section 2), if followed,
Uncontrolled
will ensure that non-classified workers do not receive an annual effective radiation dose
greater than 1mSv.
Section 4 contains copies of the forms to be used to enable a record of exposure to be
compiled for non-classified workers entering a controlled area and for controlling the
transport and disposal of radioactive waste.
Records of monitoring for contamination levels and exposure times for personnel are
required only when a controlled area has been established. It is seen as good practice to
record contamination levels in supervised areas to prove that the area is indeed
under supervision.
5 Airborne Contamination
The aim of these procedures is to prevent the generation of airborne contamination.
The Ionising Radiations Regulations require that, should contamination levels potentially
give rise to effective radiation doses above given levels, controlled or supervised areas
may be required to be designated.
As with sealed sources, the definition of controlled and supervised areas are as follows:
• Controlled area
- An area in which persons are likely to exceed a radiation dose of 6mSv in 1 year
- An area where control measures are used to ensure that persons do not receive an
annual radiation dose in excess of 1mSv
• Supervised area
- An area in which persons are likely to exceed a radiation dose of 1mSv in 1 year
Airborne contamination is difficult to assess and is not routinely measured.
These procedures should reduce, or negate, the production of airborne contamination.
Unlike the old regulations, there are no figures on which to ‘hang’ a designated area;
again each task must be risk assessed.

For ease of use, the following will be implemented:

• Controlled areas will exist when:
- A prior risk assessment indicates the person is likely to exceed 6mSv/year
- Whole body radiation dose rate exceeds 7.5µSvh-1, with no LSA/NORM present
(ie nucleonics attached to or within a vessel)
- The first person to enter a vessel to confirm a safe situation (ie shutter mechanism
on nucleonics is closed). The area may then, providing no radioactive
contamination is present, be de-designated
- Cleaning contractors, or Installation/site staff, while carrying out cleaning
operations inside vessels, measure radiation contamination levels in excess of
double background (major cleaning operation)
Uncontrolled
- Installation/site staff, or cleaning contractors, while decontaminating (cleaning)

equipment on deck, may, to control the potential spread of contamination,
designate a controlled area
Note: Controlled areas must be demarcated, display the trefoil symbol and suitable
warning sign to explain the nature of the hazard, eg ‘Radiation Controlled Area’,
‘Alpha Radiation Internal Hazard’.
• Supervised areas will exist when:
- The radiation whole body dose rate exceeds 2.5µSvh-1
- The prior risk assessment indicates that a person is likely to exceed 1mSv/year
- Breaking open pipework to check for the possibility of LSA material.
Although dustmasks and other Personal Protective Equipment (PPE) will be worn
during these operations, it will not be worn solely to keep effective dose below
1mSv/year, but to limit the possibility of ingesting other contaminants.
This is therefore not a control measure as described by IRR99
- Cleaning contractors may decide to create a supervised area within a given
distance of the controlled area
Supervised areas must display the trefoil symbol, and suitable warning signs to explain
the nature of the hazard, eg ‘Radiation Supervised Area’, ‘Alpha Radiation
Internal Hazard’.
6 Radiation Passbook
Although the Ionising Radiations (Outside Workers) Regulations 1993 have been
integrated with the new IRR99, the radiation passbook is still in operation. If a classified
worker operates in a third-party’s controlled area, that party must assess the worker’s
radiation dose and make an appropriate entry into the worker’s radiation passbook.

7 The Radiation Protection Supervisor (RPS)

The RPS is responsible for supervising the work with ionising radiations onsite.
Supervision will include such things as:
• Advising on the designation and signing of controlled and supervised areas
• Confirming the suitability of designating temporary supervised and controlled areas
• Ensuring that suitable, properly calibrated dose rate and surface contamination
monitoring equipment is available
• Ensuring that radiation dose rates and surface contamination measurements are
made and recorded, at least quarterly
• Ensuring that the radiation dose rates for all workers employed in controlled areas
are assessed
Uncontrolled
• Ensuring that work is carried out and records are kept in accordance with the relevant
local rules and procedures
• Confirming that access to controlled and supervised areas is restricted to
authorised persons
• Ensuring that persons authorised to enter supervised and controlled areas have
received suitable training in radiation protection
• Ensuring that measures are taken to prevent the spread of LSA contamination from
the site of scale production, or from supervised and controlled areas
• Ensuring that representative samples of radioactive material are taken and sent for
radiochemical analysis, the weight of the material disposed of to sea is recorded and
the total activity calculated. This should be estimated before each job to ensure
the Installation does not exceed its authorisation.
The weights and total activity of radioactive material removed from contaminated
equipment onshore are to be recorded by the cleaning company. A copy of these
records is to be retained on the Installation
• Ensuring supervised/controlled areas are free from contamination before restrictions
are lifted
• Maintaining records of the transport and disposal of radioactive waste
• Identifying potential radiological problems and passing them and other relevant
information to the RPA

7.1 List of RPSs for Installation/Field
<enter names>
RPA: Synetix Tracerco
Unit 4
The Technology Centre
Offshore Technology Park
Claymore Drive
Bridge of Don
Aberdeen
AB23 8GD
Principal contact: Graham R Wales
Tel: (01224) 826628
Uncontrolled
Secondary contacts: William Good

John Lambley
or
Dr Paul Warren
Dr David Couzens
Tel: (01642) 375500

Section 2
The Ionising Radiation Regulations 1999,
Regulation 18(2) BP Written Arrangement
for Working in a Controlled Area Due to
Levels of LSA Scale
(1) This written arrangement applies to non-classified persons who must be aged 18 years
or over, and who are working in a radiation controlled area, for the purposes of inspection,
maintenance or operation of relevant equipment.
Uncontrolled
Contractors’ non-classified personnel who may occasionally need to carry out work on
equipment within a controlled area must also be subject to this written arrangement.
However, they should only be allowed into a controlled area with the agreement of
their employer.
This written arrangement is not intended to be used for contractors whose principal work
activities involve them directly with Low Specific Activity (LSA) material, eg LSA cleaners.
(2) A controlled area under this written arrangement means any area in which either:
• The equivalent dose rate is greater than 7.5µSvh-1
• A prior risk assessment indicates that, in that area, an employee is likely to
exceed 6mSv in 1 year
• A control measure is in place to prevent the annual dose to that person exceeding
1mSv/year
(3) ‘Relevant equipment’ in Item (1) means any production, and associated equipment,
which is contaminated or is likely to be contaminated by LSA material.
(4) No person shall be employed in a controlled area in the processes specified in Item (1)
unless an assessment has been made of the individual’s radiation dose, to date.
Only when the Company is satisfied that the potential radiation dose will not result in that
individual exceeding 6mSv will that person be allowed access to the controlled area.
(5) No person shall dwell longer than necessary in a controlled area.
(6) A record, ‘Radiological Exposure of a Non-classified Worker’, shall be kept for each person
employed in accordance with this written arrangement. A sample record and guidance on
completion and retention are included in Section 4 Paragraph 4 and Section 1 Paragraph 4,
respectively.
(7) No person shall be employed in a controlled area or engaged in the maintenance, cleaning
or manipulation of relevant equipment unless a relevant Permit to Work has been issued.
(8) Every work permit issued for the purposes of Item (7) shall state:
• The name of the person to whom it is issued
• The relevant equipment and work to which it refers
Part 2 The Ionising Radiation Regulations 1999, Regulation 18(2)

• The local rules under which the work is to be carried out

• The period of time for which it is valid
The work permits shall be signed by the Area Authority and countersigned by the
Radiation Protection Supervisor (RPS).
(9) Any person working in accordance with the conditions of a work permit, specified in
Items (7) and (8), shall wear suitable protective clothing as specified in the appropriate
local rules and work procedures.
(10) Dedicated washing, changing and monitoring facilities shall be provided as close as is
reasonably practicable to the exit from a controlled area. After decontamination,
any person leaving a controlled area must be monitored for contamination, and may be
advised to wash face and hands as soon as possible.
(11) Eating, drinking, chewing of gum, or other actions which might encourage the ingestion
Uncontrolled
of contamination, is prohibited.
(12) Minor cuts, grazes etc must be covered with suitable waterproof adhesive dressings
before entry to the area. Any minor cuts and grazes received while working in the
controlled area must be reported immediately to the RPS and appropriate first aid
treatment obtained.
(13) All reasonably practical measures, as specified in the relevant local rules, shall be taken to
eliminate the production of airborne radioactive material and to control surface
contamination to prevent the spread of contamination outwith the controlled area.
(14) On completion of work and before removing the restrictions, radiation dose rate and
contamination monitoring shall be carried out to ensure they are less than or equal to the
background level.
Where it is not possible to decontaminate to these levels, then the area must remain
supervised or controlled and appropriate precautions taken and records amended.
(15) The equivalent dose rate shall be measured frequently whilst work is being carried out
in a controlled area or on relevant equipment. In the event that a dose rate exceeds
30µSvh-1, work shall not start in that area or on that equipment and the RPS shall be
notified immediately.
Work may be allowed to commence under new terms, which will be specified after
consultation with the Radiation Protection Adviser (RPA).
(16) The local RPS must ensure that workers employed under this written arrangement are
familiar with the procedures laid out in it and in any relevant local rules that are in force.
(17) Records of written arrangements, which will include a radiation dose assessment,
shall be kept by the RPS for the calendar year to which they apply.
(18) Permits to work will be retained on the Installation for a period of 3 years.
(19) Records relating to long-term supervised or controlled areas (refer to Item (13)) shall be
kept by the RPS until restrictions can be lifted and retained for a minimum of 5 years after
the date when restrictions were lifted.
The Ionising Radiation Regulations 1999, Regulation 18(2) Part 2

Section 3
Local Rules
Paragraph Page
1 Entry, Inspection and Repair of Large Vessels 3-1
2 Inspection and Maintenance of Equipment Suspected

of Being Contaminated with LSA Radioactive Material 3-5
3 Cleaning of Items of Equipment Contaminated with

Uncontrolled
LSA Radioactive Material 3-7
4 Pulling Well Tubing Contaminated with

LSA Radioactive Material 3-9
5 Transportation and Disposal of Equipment

Contaminated with LSA Radioactive Material 3-13
Appendix 3A Guidance for the Completion of Record Forms
Appendix 3B Radiation Monitoring Instruments
Appendix 3C Packing and Labelling of Consignments of

Equipment Contaminated with LSA Material
for Transportation
Appendix 3D Installation Authorisation Certificates
Part 2 Local Rules

1 Entry, Inspection and Repair of Large Vessels

(1) These local rules apply to work on or inside vessels affected, or potentially
affected, by Low Specific Activity (LSA) radioactive material. They apply in addition
to normal work permit requirements. Since these vessels may be, or may give
rise to, controlled or supervised areas, work shall only proceed when suitable,
calibrated radiation dose rate and surface contamination monitors are available.
The rules will be implemented under the guidance of the Installation
Radiation Protection Supervisor (RPS), and in accordance with the measures
described below.
(2) Before any work is carried out on the vessel, equivalent dose rates shall be
measured external to the vessel in order to give a preliminary indication of the
extent of the internal deposits. If present, attempts shall be made to remove loose
Uncontrolled
deposits from the vessel by remote means such as sand or jet washing.
These deposits may also be contaminated and if so should be disposed of in
accordance with Item (12) of these local rules and the conditions within the
relevant certificate of authorisation for the accumulation and disposal of radioactive
waste for the Installation.
Note: Should initial external dose rate readings not be above background it
should still be assumed that LSA scale will be present, at some level,
within the vessel.
(3) Prior to work commencing, a marked area (of practical size) will be set up at the
points of access to the vessel and at any points where pipework is to be
disconnected from the vessel. Eating, drinking, etc will be prohibited within
this area.
(4) Where safe to do so, the marked area(s) shall have the recommended heavy-duty
sheeting laid on the floor or scaffolding platform, and shall be cordoned off and
clearly marked. Suitable (washable/disposable) Personal Protective Equipment
(PPE) will be worn by all who enter these areas. Water and paper towels shall also
be provided for decontamination, the latter being safely disposed afterwards in
accordance with local rules.
(5) It should be assumed that the marked areas could become contaminated to
some degree. Entry to them shall therefore be strictly limited to workers working
in accordance with these local rules. Prior risk assessment based on radiation dose
rates and contamination measurements will dictate if the areas are supervised or
controlled. If the area is designated a controlled area, entry shall be restricted to
classified workers or persons working in accordance with the written arrangement.
(6) Persons entering a controlled area, where there is a risk of airborne contamination,
and the ventilation rate is less than 10 air changes per hour, will use self-contained
or air line breathing apparatus. In addition, where cleaning is carried out in
controlled or supervised areas, respirators must be worn. The type of respirator
worn will depend on the nature, activity and amount of dust or spray being
produced. Should there be any doubt, use self-contained or air line breathing
apparatus.
Part 2 Local Rules

(7) When pipework is disconnected from the vessel, the RPS shall take
measurements to ascertain whether contamination is present inside the pipework.
If so, the ends of the pipework shall be sealed, eg wrapped with plastic sheeting or
provided with blanking plates, and any smaller items such as gasket rings shall be
sealed in marked plastic bags.
Note: The prior risk assessment may highlight the need to wear dustmasks or
other respiratory apparatus to protect against radioactive or other
contaminants.
(8) After the access points to the vessel have been opened, the interior of the vessel
shall be hosed down to remove any remaining loose material. So far as is possible,
this should be done from the points of access, and before anyone enters
the vessel. If it is likely that contaminated dust or spray will be inhaled, respirators
shall be worn as detailed in Item (6).
Uncontrolled
(9) The RPS and where appropriate in conjunction with the cleaning company RPS,
shall make an initial assessment of the radiation hazard by measuring radiation
dose rates and contamination levels through the access point.
Note: Contamination monitors are not intrinsically safe and should not be used in
an area where recently broken containment has taken place. If a risk of
flammable material is present, a sample of the contaminant should be
removed from the vessel and measured outwith the area of risk.
The BP RPS shall enter the vessel, wearing suitable PPE, and make radiation dose
rate and surface contamination measurements within all accessible areas of
the vessel. Using these figures the RPS will carry out a risk assessment and
declare the vessel either free of contamination, contaminated but free for normal
working, a supervised area or a controlled area.
Note: If nucleonic gauging equipment is attached to or located inside the vessel,
a controlled area will be declared until dose rate measurements are made
to confirm the status of the source and shutter mechanism. Once the
shutter is confirmed closed and the radiation dose rates are at acceptable
levels, the area can then be de-designated.
A normal work permit shall be issued for a vessel free of contamination.
If contamination is present, the work permit shall specify that work continues in
accordance with these local rules.
If the vessel is declared a controlled area, entry shall be strictly limited to classified
workers or persons working in accordance with the BP written arrangement.
Work will not proceed if the measured whole body radiation dose rate exceeds
30µSvh-1 at which point the RPS shall notify the Offshore Installation Manager
(OIM)/Site Manager and the RPA.
(10) Where a controlled area has been designated and the proposed work in that area
entails the use of contractors’ classified workers, consideration may be given by
the RPS to handing over the controlled area to the contractor. If this is the
preferred route, the handover shall be done in writing using the appropriate
certificate and a copy maintained on file (refer to Section 4 Paragraph 6).
Local Rules Part 2

(11) Workers authorised in accordance with the vessel’s area designation may now
enter the vessel. If high-pressure waterjetting or wet grit blasting is to be
carried out, workers shall wear approved breathing apparatus or filter respirators in
addition to their protective clothing, as detailed in Item (6). For other operations
inside the vessel, workers shall wear a filter respirator and protective clothing as in
the approved list. In addition, the risk of vapours or fumes arising from disturbed
sand/scale/sludge should also be taken into account when deciding on respiratory
protection. Until such risk has been fully removed, breathing apparatus should
be used.
(12) Where surface contamination monitoring confirms that radiation contamination
levels just above background are present, it is important to remember that, should
the contamination become airborne, controlled or supervised areas may require to
be designated (refer to Section 1). Where any surface contamination is present
that requires removal, this shall only be done by wet methods.
Uncontrolled
(13) If an area in or around a vessel has been declared a controlled area,

the RPS shall ensure that a record of the estimated radiation exposure is kept for
each non-classified worker who enters the area, as detailed in the BP written
arrangement.
(14) Drainage from the vessel shall be discharged via a suitable mesh screen or weir
system to a drain hose whose outlet is below sea level. The conditions stated
in the relevant Certificate of Authorisation for Accumulation and Disposal of
Radioactive Waste for the Installation must be complied with.
(15) For bulk LSA material from offshore Installations, the preferred disposal option is
by discharge to sea under the conditions of the specific Installation authorisation.
Should it not be possible to use this route, the Installation RPS must contact the
Radiation Protection Adviser (RPA) for advice.
Note: Under no circumstances should ‘radioactive waste’ material be disposed of
to the beach without the agreement of the RPS and an identified
authorised disposal route.
‘Radioactive waste’ does not include samples sent to the beach for analysis,
or contaminated equipment sent to stipulated cleaning companies (refer to
Certificate of Authorisation).
(16) When any components inside the vessel are loosened for removal, any small
amounts material/scale which might be released shall be washed away.
The component parts themselves shall be cleaned, as far as possible, before they
are removed from the vessel.
(17) All items of equipment removed from the vessel shall be monitored for
contamination. If contamination greater than background is present and cannot
be removed within the designated area, the items shall be wrapped in
heavy-duty polythene sheet and labelled as LSA contaminated prior to their
removal to another designated storage or cleaning area. Items to be cleaned shall
be cleaned in accordance with the local rules for cleaning contaminated equipment
(refer to Paragaph 3).
Part 2 Local Rules

(18) Prior to any worker leaving the area, protective clothing shall be washed down to
remove any loose contamination.
(19) Before any worker is allowed to leave a controlled or supervised area, protective
clothing shall be monitored for contamination. If any contamination is present,
it shall be washed down until the surface contamination is not measurable above
background. Should paper towels be used in the process, they shall be stored in a
marked receptacle to await safe disposal. All protective clothing used in controlled
or supervised (dirty) areas shall be removed before leaving the area. The worker
shall be advised to thoroughly wash his face and hands as soon as possible.
Note: It is permissible, where practicable, for clothing to be decontaminated and
used again.
(20) All tools and ancillary equipment used inside the vessel shall be monitored for
contamination when removed from the vessel. If surface contamination is present,
Uncontrolled
it shall be removed with water and/or paper towels, the latter being safely
disposed of in accordance with local rules.
(21) Any items of equipment which are contaminated above background must be
decontaminated prior to disposal, in accordance with the local rules for the
transportation and disposal of equipment contaminated with LSA radioactive
material (refer to Paragraph 5).
(22) On completion of the work, the floor coverings used in the controlled or supervised
area shall be removed and monitored for contamination. If contamination is
present, the floor shall be cleaned to background level.
(23) On completion of the work, all drains used within the controlled or supervised area
shall be flushed with copious amounts of water. A radiation contamination monitor
will be used to confirm the contamination levels are not higher than background.
(24) All combustible, potentially contaminated or contaminated waste, such as paper
towels and clothing, shall be securely wrapped in plastic bags before they are
removed from the controlled or supervised area. All loose contamination shall be
removed from the clothing, by wiping or washing down prior to bagging the
clothing for disposal.
The bags shall be clearly marked ‘Soiled Combustible Waste Material –
For Incineration Only’.
From offshore, bags shall be sent to the supply base for disposal at the end of
the job. Prior to shipment, the Nominated Person (NP), and the Shipping Controller
of the supply base, shall be faxed with details of the shipment.
Onshore, the person responsible for the control of waste shall ensure that the
material is disposed of in the appropriate manner.
Note: This paragraph does not relate to loose LSA material which must be
disposed of in accordance with the detailed conditions within the relevant
certificate of authorisation for accumulation and disposal of radioactive
waste for the Installation. Loose or bulk scale must never be sent for
onshore disposal.
Local Rules Part 2

(25) The RPS shall ensure that representative samples of the radioactive
contamination encountered in the vessel are taken and sent to the RPA who will
arrange for a quantitative radiochemical analysis to be carried out to determine the
specific activity (Bqg-1) of the material. As a guide, approximately 100 grams of
sample are sufficient for analysis. Results of the analysis will be sent to the
Installation RPS who will use them to calculate the total activity disposed of to sea.
If more than one form of scale is identified a sample of each form should be taken
and tested.
Note: ‘Representative samples’ means at least one sample of each form of LSA
scale, eg sand, sludge or hard scale.
(26) On completion of the work the RPS shall make an estimate of the total weight of
LSA material that was disposed of to sea. If the amount was greater than 1 kg,
details of this estimate shall be recorded in the appropriate disposal register,
Uncontrolled
where a record of the radium 226, radium 228 and overall total activity disposed of
will be maintained.
For jobs involving quantities of scale not greater than 1kg, there is no need to keep
a record of its disposal to sea.
Note: Only figures greater than the figure given in the Phosphatic Substances etc
Exemption Order 1962 (14.8Bq/g) need be recorded. This figure can be
derived from individual sample analysis as follows:
Radium 226 figure x 2 + actinium 228 figure x 1.7
The Installation must retain records of the radioactive material disposed of to sea,
and have access to the records for the material disposed of to the beach as
contaminated equipment. The equipment records are usually available from the
cleaning company. These records will be required to complete the disposal returns,
sent annually to the Scottish Environment Protection Agency (SEPA).
2 Inspection and Maintenance of Equipment Suspected

of Being Contaminated with LSA Radioactive Material
(1) These local rules apply to work on process equipment in areas affected or
potentially affected by LSA material. They apply in addition to normal work permit
requirements. Radiation dose rate and contamination monitors will be used as part
of the risk assessment to designate controlled or supervised areas, as necessary.
This will be done under the guidance of the RPS and in accordance with the
measures described below.
(2) A marked area, of practical size, shall be set up around the piece of equipment to
be worked on. Eating, drinking etc will be prohibited within the marked area.
(3) Where safe to do so the marked area shall have heavy-duty sheeting laid on the
floor, or scaffolding platform. The area shall be demarcated and clearly signed.
Persons who are to carry out the work will wear the appropriate PPE at all times.
Water and paper towels shall also be provided for personal decontamination,
the latter being safely disposed of afterwards in accordance with local rules.
Part 2 Local Rules

(4) Entry to the area shall be strictly limited to workers working in accordance with
these local rules.
(5) When the equipment has been opened up, the RPS shall make additional radiation
dose rate and surface contamination measurements to confirm the correct
designation of the area.
A normal work permit shall be issued for equipment free from contamination.
If contamination is present, a work permit shall specify that work will continue in
accordance with these local rules. If a controlled area is designated, entry to the
area shall be strictly limited to persons working in accordance with the BP written
arrangement or classified workers. Work shall not proceed if the measured dose
rate exceeds 30µSvh-1 when the RPS shall notify the OIM/Site Manager and
the RPA.
(6) Where it is practical, component parts shall be hosed down in situ before they are
Uncontrolled
removed. If there is a possibility of the persons carrying out this operation inhaling
or ingesting radioactive material, they must wear approved respiratory protection.
All components, tools, etc removed from the equipment shall be monitored
for contamination.
If the contamination cannot be removed within the designated area, the items shall
be wrapped in a heavy-duty polythene sheet prior to their removal to another
designated storage or cleaning area. Items to be cleaned shall be cleaned in
accordance with the local rules for cleaning contaminated equipment (refer to
Paragraph 3).
(7) Items of equipment which are contaminated to a level above the measured
background must be decontaminated prior to being scrapped or sent for
renovation, in accordance with the local rules for the transportation and disposal of
contaminated equipment (refer to Paragraph 5).
(8) The RPS shall ensure that representative samples of the radioactive contamination
are taken and sent to the RPA, who shall arrange for radiochemical analysis to be
carried out. Results of the analysis performed will be sent to the Installation RPS.
marked receptacle to await disposal. All protective clothing used in controlled or
supervised (dirty) areas shall be removed before leaving the area. The worker shall
be advised to thoroughly wash his face and hands as soon as possible.
used again.
(10) If an area has been declared a controlled area, the RPS shall ensure that a record of
the estimated radiation exposure is kept for each non-classified worker who enters
the area, as detailed in the BP written arrangement.
Local Rules Part 2

(11) Any loose solid radioactive material (greater than 1kg) should be placed in a
suitably labelled container to await disposal. A sample of the contents should be
sent for radiochemical analysis to allow total activity figures to be calculated.
The material should be disposed of, as soon as practicably possible, to sea,
in accordance with the Installation’s certificate of authorisation.
(12) On completion of the work, any tools and equipment used shall be monitored
for contamination. If any contamination is present, this shall be removed by
washing and, if necessary, the use of paper towels.
(13) On completion of the work, the floor covering used in a controlled or supervised
area shall be removed and the floor shall be monitored for contamination.
If contamination is present, the floor shall be cleaned to background levels.
Uncontrolled
(15) All combustible, potentially contaminated waste such as paper towels and clothing
(refer to Paragraph 1 Item (23)) shall be securely wrapped in plastic bags before
they are removed from the supervised or controlled area. The bags shall be clearly
marked ‘Soiled Combustible Waste Material – For Incineration Only’. Disposal of
the bags shall be as detailed in Paragraph 1 Item (23).
(16) On completion of the work, the RPS shall make best estimate of the total weight
of LSA material that was disposed of to the sea. If the amount was greater
than 1kg, details of this estimate shall be recorded in the appropriate offshore
disposal register where a record of the total radium 226 and radium 228 activity
and the overall total activity disposed of shall be maintained, for inspection
by SEPA.
Where contaminated equipment is sent to an authorised decontamination facility,
the RPS shall record the despatch in the onshore disposal record and await
confirmation from the contractor of the quantity and specific activity of scale
removed for final record completion.
3 Cleaning of Items of Equipment Contaminated with

LSA Radioactive Material
(1) These local rules shall be applied when it is necessary to clean items of equipment
contaminated with LSA material.
(2) A controlled or supervised area shall be set up, as appropriate, following the initial
risk assessment, in which the cleaning operations are to be carried out.
Eating, drinking, etc will be prohibited in the area.
(3) It is the responsibility of the Installation RPS, possibly in conjunction with the
contractor’s RPS, to designate controlled or supervised areas. If the area is
covered, they should ensure that it is of sound construction.
Part 2 Local Rules

The controlled or supervised area shall be set up in such a way as to prevent the
spread of radioactive contamination. The RPS should ensure that any radioactive
fluids caused by the cleaning process are disposed of via a suitable drain to sea.
Suitable PPE shall be available at the entrance to the areas. Water and paper
towels shall also be provided for personal decontamination.
(4) The preferred method for cleaning is by high-pressure waterjetting. If mechanical
means are used, the item of equipment being cleaned shall be kept wet at all
times to prevent the production of airborne contamination.
(5) If high-pressure jetting is being used, air line breathing apparatus or approved
respirators should be worn. If mechanical means are being used, filter respirators
should be used. If a controlled area is designated, work must be carried out by
classified workers or in accordance with the BP written arrangement.
(6) When items have been cleaned to a satisfactory mechanical condition, they should
Uncontrolled
be monitored to check for residual radioactive contamination. If contamination
above background levels is measured, the items shall be wrapped in plastic bags,
and labelled, before they are removed from the designated area and until they are
reinstalled in the plant. If no contamination is present, the items can be handled in
a normal manner.
marked receptacle to await disposal. All protective clothing used in controlled or
supervised (dirty) areas shall be removed before leaving the area. The worker shall
be advised to thoroughly wash his face and hands as soon as possible.
used again.
(8) If an area has been declared a controlled area, the RPS shall ensure that a record of
the estimated radiation exposure is kept for each non-classified worker who enters
the area, as detailed in the BP written arrangement.
(9) Any loose solid radioactive material (greater than 1kg) should be placed in a
suitably labelled container to await disposal. The material should be disposed of,
as soon as practicably possible, to sea, in accordance with the Installation’s
certificate of authorisation.
(10) The RPS shall ensure that representative samples of the radioactive contamination
encountered are taken and sent to the RPA who will arrange for radiochemical
analysis. Results of the analysis performed will be sent to the Installation RPS.
(11) On completion of the work, any tools and equipment used shall be monitored for
contamination. If any contamination is present, this shall be removed by washing
and, if necessary, the use of paper towels.
(12) On completion of work and before removing the restrictions, designated areas
must be monitored. The contamination levels and radiation dose rates must not be
measurable above background.
Local Rules Part 2

Where it is not possible to decontaminate to these levels, then the area must
remain controlled or supervised, the appropriate precautions taken and records
amended to identify the continuing status of these areas.
(13) All combustible, potentially contaminated waste such as paper towels and clothing
(refer to Pargaraph 1 Item (23)) shall be securely wrapped in plastic bags before
being removed from the supervised or controlled areas. The bags shall be clearly
marked ‘Soiled Combustible Waste Material – For Incineration Only’.
(14) From offshore, the bags shall be sent to the supply base for disposal at the end of
the job. Prior to shipment the Shipping Controller of the supply base shall be faxed
with details of the shipment.
Uncontrolled
(16) On completion of the work, the RPS shall make an estimate of the total weight of
LSA material that was disposed of to sea. If the amount was greater than 1kg,
details of this estimate shall be recorded in the appropriate offshore disposal
register where a record of the radium 226, radium 228 and overall total activity
disposed of shall be maintained for inspection by SEPA.
4 Pulling Well Tubing Contaminated with

LSA Radioactive Material
(1) These local rules must be applied when it is known or suspected that the well
tubing to be pulled have internal or external surface contamination.
Note: The local rules for inspection and maintenance of equipment (refer to
Section 2) apply to the removal of flowlines, xmas trees etc. The early
identification of LSA material at this stage will assist in the implementation
of the following procedures.
(2) A Permit to Work (PTW), countersigned by the RPS, must be issued by the Area
Authority to allow the opening of any equipment which is known or suspected to
contain LSA material.
(3) Prior to pulling tubing, the working area of the drill floor, excluding the doghouse,
shall be marked and designated as a supervised area. Entry to this area shall be
strictly limited to those working in accordance with these local rules.
Eating, drinking etc will be prohibited within the marked area.
Part 2 Local Rules

(4) Only if safe and practicable will the floor of the designated area be covered with
the recommended sheeting.
The recommended protective clothing comprising one-piece waterproof or
impervious coveralls, gloves, boots, respirators and disposable earplugs shall be
available at the entrance to the drill floor.
This clothing must be worn by workers handling uncapped tubing.
(5) Water and paper towels shall be provided inside designated areas for the
decontamination of protective clothing.
(6) The first five joints of tubing recovered shall be monitored by the RPS for
contamination. If contamination greater than background is found, the area shall
remain supervised. If a risk assessment indicates that there is a possibility of
persons receiving a radiation dose greater than 6mSv/year, the area shall be
Uncontrolled
upgraded to a controlled area when the BP written arrangement shall apply.
Note: It is unlikely that a person undertaking this work will receive a radiation
dose of 6mSv/year. The wearing of PPE could be defined as a control
measure, thus requiring a controlled area. However, the PPE is worn to
prevent possible ingestion of other contaminants and not primarily to keep
the radiation dose below 1mSv/year.
If no contamination is measured, restrictions may be relaxed, but the
contamination level shall continue to be measured every 10 joints or when the
interior condition of the tubing appears to change, if this is sooner.
Where contamination is only found some time after tube pulling has commenced,
the tubing removed since the previous measurements must be monitored to
determine on which tubular contamination first appeared.
If any contamination is measured above background in a tubular, that tubular and
all subsequent tubing must be decontaminated prior to onshore refurbishment or
disposal in accordance with the local rules for the transport and disposal of
equipment contaminated with LSA radioactive scale (refer to Paragraph 5).
Note: To monitor contamination levels inside tubing, the probe face must be
directed towards the inside wall of the tubular. With certain probe designs,
it is almost impossible to do this. For this reason, as well as consistency,
when monitoring the inside of tubing a DP2 type probe, in conjunction with
an NE Technology PCM5/Electra, should be used. However, if the internal
diameter of the tubing is too small to allow the DP2 probe to enter the
tubular, an alternative monitor, eg Mini Monitor Series 900 with Geiger
tube probe (EP15/EP15F/EL), should be used. The alternative to the
PCM5/Electra contamination monitor with DP2 probe should only be used
when there are access problems to the area to be monitored.
Local Rules Part 2

(7) If contamination is found and the drill floor working area is designated a controlled
or supervised area, then all personnel working on the drill floor must wear suitable
PPE. Respirators are required if the area is controlled or supervised and workers
are likely to inhale airborne contamination.
The wearing of full-face-mask type respirators can be a problem when working on
the drill floor as they become splashed with liquid and vision can be severely
impaired. This is a major safety consideration.
The fact that this work is carried out in the open air together with the fact that the
contamination is normally wet means that generally a disposable respirator will be
sufficient. A 3M type 8835 or equivalent can be used at the discretion of the RPS.
If personal contamination becomes a problem, the possibility of contamination of
the face must be considered by the RPS and the use of the recommended full-face
respirator reconsidered.
Uncontrolled
If personal contamination does become a problem, the RPA shall be notified

immediately.
Before any worker is allowed to leave a designated area, protective clothing must
be monitored for contamination. If any contamination is present, it shall be wiped
down using wet paper towels until the contamination is less than background
levels. All protective clothing used inside a controlled or supervised area shall be
removed before leaving the designated area and personnel shall be advised to
wash their faces and hands.
(8) Before each tubing connection is broken, it shall be checked to ensure that it is
drained of fluid. The bottom of each joint of contaminated tubing shall be capped
with a solid cap immediately the connection is broken or immediately after
carrying out the contamination survey.
The joint must be capped while it is still hanging vertically. As the joint is swung
out through the ‘V’ door, the top of the joint shall then be capped with a solid cap.
(9) Each joint of any tubing contaminated above background shall be clearly marked
with an identification number and labelled ‘Low Specific Activity Contamination’.
The identification number shall be such that the well number and the position of
the joint in the well can be identified.
Part 2 Local Rules

(10) Isolated incidents have occurred when tubing have been found to be contaminated
with LSA scale on the external surfaces of the tubular.
If this is found to be the case, the following actions shall be taken:
(a) Prevent the unauthorised release of contamination during shipment by
sealing any tubing inside polythene sleeves or shipping the tubing inside a
half height container lined with thick polythene sheet. Half heights with solid
sides and bottom shall be used and be covered prior to despatch.
(b) Slings etc used in lifting tubing that are contaminated with LSA material on
the outside shall be monitored and, if necessary, sent with the tubing for
decontamination.
(c) The fax, notifying the shipment of LSA contaminated equipment, shall state
that the tubing are externally contaminated.
Uncontrolled
(11) Radiation dose rate measurements shall be made from bundles of tubing on the
pipe deck. If the dose rate is greater than 7.5µSvh-1, a controlled area will be
demarcated and suitable signs displayed. Entry to this area shall be restricted and a
record maintained of those entering the area will be kept as detailed in the written
arrangement.
If the above dose rate measurement is between 2.5 and 7.5µSvh-1, the area shall
become a supervised area and entry restricted to personnel working under these
local rules.
In the absence of surface contamination, ie the radioactive material is sealed inside
the capped tubing or by the external wrapping, the requirement to wear respirators
shall not apply.
(12) The employee’s RPS shall ensure that a record is kept of the estimated radiation
dose received by all non-classified workers entering the controlled area,
as required by the BP written arrangement.
(13) Regular checks shall be made to monitor whether any contamination is present on
surfaces of the drill floor, Blowout Preventer (BOP) deck, well compartment and
pipedeck storage area. If any contamination is present, this shall be removed using
water and/or paper towels. Hosing away of contamination shall only be done when
the contamination can be directed straight to sea via drains leading to the sea
sump or mud out-fall. On completion of the work, radiation contamination
monitoring will be carried out to ensure that no residual contamination is present.
(14) Samples of any LSA material found inside the tubing string shall be taken and sent
to the RPA for radiochemical analysis to determine its specific activity for disposal
record purposes, unless the tubing is to be sent to the beach to be cleaned by an
authorised company, in which case they will carry out the analysis.
(15) All combustible, contaminated waste, such as paper towels and protective clothing
(refer to Paragraph 1 Item (23)) shall be wrapped in plastic bags before they
are removed from controlled or supervised areas. The bags shall be marked
‘Soiled Combustible Waste Material – For Incineration Only’, and sent to the supply
base for disposal. Prior to shipment the NP and Shipping Controller of the supply
base shall be faxed with details of the shipment and voyage.
Local Rules Part 2

(16) If contamination has been found within the tube string, the mud system,
including BOP etc, shall be flushed, drained and checked to ensure that no
contamination remains on completion of the workover. All tools used during the
workover must be monitored for contamination. If any is found, it shall be removed
by wiping with wet paper towels and the towels disposed of as in Item (15).
(17) The procedure for transport and disposal of contaminated tubing is detailed
in Paragraph 5.
5 Transportation and Disposal of Equipment

Contaminated with LSA Radioactive Material
Disposal of any equipment contaminated with radioactive material must be in strict
Uncontrolled
accordance with the terms of any authorisation issued by SEPA for the particular
Installation. Each Installation shall have a specific accumulation and disposal
authorisation, which must be displayed.
(1) All equipment contaminated above background with LSA radioactive material
shall be decontaminated prior to disposal.
These local rules govern the transportation of equipment for decontamination.
They apply to all equipment contaminated with LSA radioactive material, which has
a specific activity greater than 0.37Bqg-1 of the particular elements detailed in
Schedule 1 of Radioactive Substance Act 1993. In this context, ‘disposal’ means
equipment, which may later be resold, re-used or scrapped. An ‘Analysis Transport
and Disposal’ form must be completed in addition to the requirements of the local
rules. A copy of this form and guidance on its completion is included in Section 4
Paragraph 3.
The level at which action is required regarding disposal (0.37Bqg-1) is at the limit of
detection of the contamination monitors used by BP.
Therefore, any item showing contamination, measurable above the normal
background of the contamination monitor, shall be dealt with according to
the criteria of this section.
(2) For onshore decontamination, the equipment must be sent to a
company/establishment which is authorised to carry out such work by SEPA.
At present, there are three such sites authorised:
• Scotoil Services, Links Road, Aberdeen
• Dounreay Nuclear Power Development Establishment, United Kingdom Atomic
Energy Authority, Thurso, Caithness
• Score Europe, Peterhead
Part 2 Local Rules

A decision as to which contractor is to be used shall be taken before the

contaminated equipment leaves the Installation. Equipment shall not be sent
to one contractor and then transferred to the other before decontamination
has commenced.
Prior to shipment, the RPS must make a best estimate of the total weight of
radioactive material contained within the equipment where possible. Samples of
the material shall also be taken and sent to the RPA for radiochemical analysis.
(3) The loss of LSA material from any item must be prevented. This may be achieved
in the case of small items by wrapping them in thick polythene sheeting and in the
case of pipework, tubing or large items by capping or sealing each opening.
Suitable polythene bags/sheeting are available for this purpose and shall be clearly
identified with tape marked ‘LSA Contaminated’.
Uncontrolled
(4) Contaminated items suitable for containerisation must be individually labelled,
securely stowed within the allocated container and labelled specifically for that
particular consignment of equipment. The container must not contain any
materials that are not to be forwarded for decontamination.
Tubing/deck cargo must be segregated and labelled in accordance with the
appropriate transport regulations and prepared for shipment in the normal manner.
Labelling requirements are as detailed in Appendix 3C.
(5) Prior to shipment, the RPS shall ensure that each individual package including each
tubular is clearly marked with an identification number. The identification will take a
form that can be cross-referenced to the well, or part of the process plant,
the work undertaken and also any samples sent for analysis. Typically,
two systems are in current operation, one based on the ATD form serial number
and the other as outlined below, eg MLR – LSA 1/00 would represent the first item
of contaminated equipment sent in for decontamination from Miller in 2000.
In addition, tubing shall have an ID number which relates to the well of origin and
the position of the joint in the well.
It is important for statutory reporting purposes that whichever system is used,
the cross-referencing accurately reflects the origin of the equipment and the
weight and activity of LSA material present.
Items shall also be marked according to the labelling instructions.
(6) Prior to transportation, the RPS must send a fax to the cleaning company copied to
the supply base Shipping Controller and consignee. The fax shall detail the
equipment being transported, the identification numbers and vessel name and
manifest reference, Estimated Time of Departure (ETD) and Estimated Time of
Arrival (ETA).
(7) The Shipping Controller shall inform the consignee of delivery/collection
arrangements.
Local Rules Part 2

(8) The Installation RPS, NP or nominated agent shall maintain the records for bulk
LSA discharges to sea (for offshore Installations) and for contaminated equipment
specified in the ‘Certificate of Authorisation for the Disposal and Accumulation of
Radioactive Waste’ issued to the Installation by SEPA. The allocation of this
function is a Business Unit (BU) responsibility.
Where records are not maintained on the Installation, a system of regular updating
shall be agreed with the person maintaining the records.
(9) Loss or accident during the transportation of equipment contaminated with LSA
material must be reported to the RPA.
Uncontrolled
Part 2 Local Rules

Appendix 3A
Guidance for the Completion of Record Forms
Paragraph Page
1 Onshore Disposal of Low Specific Activity (LSA)

Contaminated Equipment 3A-1
2 Offshore Disposal of Bulk LSA Material to Sea 3A-1
3 Analysis, Transport and Disposal Form 3A-2

Uncontrolled
4 Personal Exposure Record Form –

Radiological Exposure of a Non-classified Worker 3A-3
5 Onsite Radiological Exposure Record Form 3A-4
6 Responsibility for a Radiation Controlled Area 3A-4
7 Shipping Instruction 3A-4
8 Shipper’s Certificate for Radioactive Material 3A-4
Part 2 Guidance for the Completion of Record Forms

November 2001 Issue 1 App 3A-i/ii

Contaminated Equipment
Refer to Section 4 Paragraph 1.
This form is retained by the Installation Radiation Protection Supervisor (RPS) and is
completed on a despatch basis for each consignment of LSA contaminated equipment
sent to an onshore, authorised decontamination contractor. At the end of each year,
the form is sent to the Radiation Protection Adviser (RPA) to allow compilation of the
annual BP report to the Scottish Environment Protection Agency (SEPA) of LSA material
disposed of.
The cross-referencing of the BP consignment number and the contractor’s certificate of
conformity (record of scale disposal) is achieved by use of the Analysis Transport and
Disposal (ATD) form number or Installation sequential LSA consignment number.
Uncontrolled
This is recorded in the ATD number column (4) and will always be quoted on the
contractor’s certificate.
The date disposed is the date when the material leaves the Installation.
The contractor is required to estimate the weight of scale removed and its specific
activity in terms of radium 226 and actinium 228 (radium 228). This will appear on the
certificate of conformity. These should be entered in columns 8, 9 and 11 respectively.
Simple calculations, as described at the bottom of the form, are required to be
completed by the RPS to complete the record in columns 10, 12 and 13.
2 Offshore Disposal of Bulk LSA Material to Sea

This form, which is very similar in layout to that for the onshore disposal of LSA
contaminated equipment, is retained by the Installation RPS and is completed on a
discharge to sea basis. At the end of each year, the form is sent to the RPA to allow
completion of the annual BP report to SEPA of LSA material disposed of.
To allow each discharge to be accurately recorded, every effort shall be made to take a
sample of the material for radiochemical analysis. The sample will be sent to the RPA,
accompanied by a completed ATD form, who will ensure that it is presented for analysis
as soon as possible. On receipt of the analysis result record, the RPA shall retain a copy
and distribute the record to the Installation RPS and Nominated Person (NP).
The analysis figures are entered in columns 6 and 8 of the form.
An estimate of the total weight of material discharged to sea supported by sample
weighing of volume measurement, will be obtained from the cleaning contractor,
shall be entered in column 5 and the calculations made, as detailed at the bottom of the
form, to complete columns 7, 9 and 10.
The cumulative record shall then be completed.

November 2001 Issue 1 App 3A-1
Each Installation has a maximum authorised disposal limit in terms of Gigabecquerels of

total activity (column 10). The cumulative amount recorded shall be reviewed by the RPS
for comparison against this limit. In the event that it is possible that the limit may be
exceeded with a forthcoming disposal, the RPS shall inform the RPA who will liaise with
SEPA over the granting of an increase in the authorised amount.
Where the records are not compiled on the Installation, it is important that regular
updates of the cumulative disposal quantity are provided to the Installation to allow
this comparison.
3 Analysis, Transport and Disposal Form

Uncontrolled
This form is the method by which all parties are notified of the movement of LSA
material samples and contaminated equipment.
Sections 3 and 4 of this form need not be completed if disposal route is to sea.
It shall be initiated by the Installation RPS and used at all times when analysis, transport
and disposal work involving LSA material is in progress.
The form is in quadruplicate and the procedure for its completion and distribution is
as follows:
(1) At the earliest opportunity, the RPS shall take a sample(s) and send it to the RPA
for radiochemical analysis.
(2) The sample(s) must be sealed and labelled identifying the origin of the sample.
This information shall be recorded by the RPS in Section 1 of the form.
The RPS shall send Copy No 1 of the form with the sample(s) to the RPA and also
fax/email advance details.
(3) On completion of the sample(s) analysis, the results are received by the RPA who
shall distribute the record to the Installation RPS.
(4) On completion of the work, the RPS shall record disposal and transport details
where applicable in Sections 2 and 3. The RPS shall retain Copy No 2 and forward
Copies 3 and 4 attached to the shipping manifest and fax/email advance details to
the NP, copied to the supply base Shipping Controller.
(5) The NP shall fax the cleaning/disposal company (consignee) and request
permission to send equipment for decontamination and request an acceptance fax.
Copies 3 and 4 of the form must be signed in Section 4 by the uplifting contractor
and the consignee confirming receipt of the equipment. The supply base shall send
Copy No 4 to the NP and retain Copy No 3 attached to the normal delivery
receipt form.
(6) The NP shall collate all necessary information and complete Section 5 of the form.
The NP will retain Copy No 4 as a total record of transport and disposal for the
specific job.
Guidance for the Completion of Record Forms Part 2

App 3A-2 November 2001 Issue 1
4 Personal Exposure Record Form –

Radiological Exposure of a Non-classified Worker
This form is required when non-classified workers are required to work in an area
designated by the RPS as a controlled area.
It is an annual personal record of the time spent in a controlled area working under the
BP written arrangement.
(1) Before permitting BP, agency or contractor non-classified personnel to work in a
controlled area, the BP RPS must have access to any previous cumulative
exposure time of work within a controlled area for the particular person.
The RPS must also ensure that the duration of the proposed work shall not cause
Uncontrolled
any person to exceed the limit of 500 hours or 6mSv per calendar year.
Note: If a person’s record is in the form of the dose they have received so far
that year, this can be converted to fit into our written arrangement
as follows.
The dose in microSieverts (µSv) they have already received should be
subtracted from 6000 (6mSv). The remainder should be divided by the
number of hours still to be worked that year to give microsieverts per hour.
The true dose rate should not exceed the calculated figure.
(2) The method for controlling and recording the exposure of personnel in a controlled
area will be by a time-in, time-out system utilising the form ‘Onsite Radiological
Exposure Record’ (refer to Section 4 Paragraph 5).
These pre-printed forms have been prepared to assist with the onsite recording of
the necessary information that requires transferring to an individual worker’s
personal record at the end of the work in the controlled area.
(3) On completion of the work, the respective employee’s RPS shall complete the
personal exposure record form by summarising the information from the onsite
Radiological Record forms completed during the work, sign it and have it
countersigned by the Responsible Person. The copies shall be distributed as
follows:
• Copy No 1 – Retained on the Installation by the RPS for the current calendar
year and for 5 years thereafter
• Copy No 2 – Sent by the RPS to the contractor’s employer with a covering letter

November 2001 Issue 1 App 3A-3
5 Onsite Radiological Exposure Record Form

This form is required on a day-to-day basis to control and record the entry and exiting of
personnel to a controlled area designated for work with LSA material.
It is also used to provide the information necessary for the operation of the BP written
arrangement for non-classified persons entering a controlled area by recording their
exposure time and area surface contamination and dose rate levels.
This information must be transferred to and retained on the individual’s personal record
(Radiological Exposure of a Non-classified Worker) for future reference and in the case of
contractor’s employees, for providing information to his employer.
Uncontrolled
6 Responsibility for a Radiation Controlled Area
This form was produced to permit the realistic estimation of radiation dose received by
classified workers only while working in a controlled area designated by someone
other than their employer. It was considered that this could best be done by handing
over responsibility for radiological protection within the area to the employer of the
classified workers.
The form is to be completed by the BP RPS and the contractor’s RPS and
countersigned/dated by each on handing back the area. A copy will be retained on file by
the BP RPS for a period of 5 years.
7 Shipping Instruction
This is the standard BP Shipping Instruction for all consignments leaving an Installation
and shall be completed under the supervision of the Installation RPS.
8 Shipper’s Certificate for Radioactive Material

This certificate is required for the despatch of any consignment of radioactive material
from an Installation to meet the requirements of the International Atomic Energy Agency
(IAEA) Regulations for the Safe Transport of Radioactive Material 1985 (amended 1990)
and the resultant UK National Air, Sea and Road Transportation Regulations.
A completed specimen certificate is contained in Appendix 3C for information.
Guidance for the Completion of Record Forms Part 2

App 3A-4 November 2001 Issue 1
Appendix 3B
Radiation Monitoring Instruments
Paragraph Page
1 Gamma Dose Rate Monitors 3B-1
2 Contamination Monitors 3B-1

2.1 NE Technology PCM5/Electra 3B-2
2.2 Contamination Monitors which use a
Uncontrolled
Geiger Tube as Detector 3B-3

2.3 Procedure to Check the Response of
Contamination Monitors 3B-3
2.4 Monitoring Procedures 3B-4
Part 2 Radiation Monitoring Instruments

November 2001 Issue 1 App 3B-i/ii
1 Gamma Dose Rate Monitors

A range of dose rate meters for work with Low Specific Activity (LSA) material is used
by BP. These include the following:
• Nuclear Enterprises IDR1/B
• Wallac RD8
• Gammatrol PRI90
• Gammatrol PRI9
The operation of such instruments shall be in accordance with the manufacturer’s
instructions.
The Nuclear Enterprises IDR1/B and the Gammatrols PRI9 and PRI90 are intrinsically
Uncontrolled
safe monitors, the Wallac RD8 is not intrinsically safe. The intrinsic safety of any other
type of dose rate meter must be checked before use.
All dose rate monitors must have been calibrated by the manufacturer prior to despatch
and at least once during any subsequent 12-month period. A current calibration
certificate shall be available on the Installation for each monitor. The certificate will be
retained for a minimum of 2 years from the date of test.
When carrying out dose rate measurements, it shall be checked whether a multiplying
factor needs to be applied to any measurement mode. Such factors, where appropriate,
should be printed on the instrument’s current certificate of test.
If a multiplying factor has been specified, the indicated dose rate reading must be
multiplied by the given factor to obtain the true dose rate.
Example:
Indicated dose rate = 7.2µGyh-1 in air
Multiplication factor ‘M’ = 1.25
True dose rate = 7.2 x 1.25 = 9µGyh-1 in air
For the type of radiation being monitored (ie that from LSA material), the Gray can be
taken as being equivalent to the Sievert.
2 Contamination Monitors
Monitors used to measure contamination resulting from the presence of LSA material
must be able to detect beta and, if possible, also alpha particle radiation. To allow these
particles to reach the detector, the foils on scintillation detectors and ‘windows’ on
Geiger tube detectors are very fragile.
If the ‘window’ of a Geiger tube is damaged, the meter will not operate.
If the foil is damaged on a DP2 probe, light will reach the photomultiplier tube and the
meter will indicate full-scale deflection.

November 2001 Issue 1 App 3B-1
BP uses a range of contamination monitors. These include:

• NE Technology PCM5 or Electra c/w DP2R dual-purpose scintillation probe
• Mini Instruments Series 900 c/w either the EP15/EP15F/EL GM probes
All contamination monitors must be calibrated by an approved agency to allow the
quantity of surface contamination in terms of Becquerels cm-2 (Bqcm-2) to be estimated
from the meter reading. This must be carried out at least once in every period of
12 months or after any repair that could have altered the calibration characteristics of the
instrument. The test certificates must be retained for a minimum of 2 years from the
date of test.
Contamination monitors, when supplied by the manufacturer, will be accompanied by a
calibration certificate for test sources that may not be appropriate to their intended use.
For monitors used in work with LSA material, these will require calibration against test
Uncontrolled
sources of similar material.
A current calibration certificate giving the relationship between the instrument reading in
counts per second and the contamination level in Bqcm-2 for LSA material shall be
available on the Installation.
The relationship between counts per second (cps) and Bqcm-2 for radium 226 with its
daughters present in equilibrium should be printed on the side of the instrument.
Where appropriate the instrument operating voltage is also given and this, together with
the zeroing, battery condition functions and the response to the test source,
shall be checked each time the instrument is used.
2.1 NE Technology PCM5/Electra

The rate meter and probe of this instrument are calibrated as a matched pair and must
not be exchanged, otherwise the calibration is invalidated.
If a foil is damaged on the Dual Purpose (DP2) probe, it can be replaced, but the
following procedure must be implemented:
(1) Remove the protective grille from the front of the detector by removing the
four screws.
(2) Remove the foil after removing the remaining 12 screws.
(3) Fit the new foil. Ensure that the sealing gasket is fitted between the foil retaining
ring and probe housing.
(4) Refit the grille.
(5) Check the sensitivity of the instrument, using the instrument response check
procedure as described in Paragraph 2.3. If the instrument reading is more
than 20% or less than 20% of the reading taken following the annual calibration,
the meter and probe shall be returned for recalibration.
Radiation Monitoring Instruments Part 2

App 3B-2 November 2001 Issue 1
Care must be taken not to damage the plastic scintillator when replacing the foil.
There should be no requirement to remove the plastic scintillator which is situated
behind the foil. However, if this is removed, it must be replaced with the clear side
facing into the probe and the white or opaque side facing the foil. If the plastic
scintillator is not replaced, the instrument will not work. If it is replaced upside down,
it cannot detect alpha particles and light photons cannot reach the photomultiplier tube.
Sudden changes in count rate when moving the probe may indicate a faulty connection
in the co-axial cable connecting the probe and meter. This cable can be changed without
the need for recalibration, provided the instrument response to the previous
pre-performance check is satisfactory when the new cable has been fitted.
2.2 Contamination Monitors which use a Geiger Tube as Detector

Uncontrolled
This type of instrument is less sensitive than that using the DP2 probe and shall only be
used when access to the area to be monitored is difficult using the DP2.
A Geiger tube ‘thin-end window’ cannot be replaced. If the window is broken, the Geiger
tube must be replaced and the instrument recalibrated by an approved agency.
2.3 Procedure to Check the Response of Contamination Monitors

This procedure is used to verify the continuing acceptable performance of a
contamination monitor and shall be carried out prior to any monitoring exercise.
The type of test source used may be in the form of a sealed scaled surface or
low-activity test disc (about the size of a 10p coin) emitting alpha or beta radiation,
eg americium 241 or strontium 90.
(1) When a monitor is returned from statutory calibration, the detector shall be placed
on the source in a position that can be repeated on later checks. If the monitor has
a radiation-type selection facility, it should be set on the alpha plus beta or
beta range. Both readings can be used for check purposes.
(2) The count rate shall be recorded.
(3) On an as-used basis, daily if the instrument is used daily or prior to use if the
instrument is used infrequently, the response check shall be repeated.
The detector shall be placed in exactly the same position with respect to the
instrument test source to ensure reproducibility of measurement. Remember to
ensure the instrument setting also remains consistent.
(4) If the count rate varies by more than ± 20% of the count rate measured
immediately following calibration, the instrument shall be returned to the Radiation
Protection Adviser (RPA) for recalibration.
The above procedure assumes the battery condition is satisfactory and the HV is
correctly set, if appropriate. These shall be checked each time the instrument is used.
This procedure shall also be used when new foils have been fitted to DP2 probes to
ensure the response is satisfactory.

November 2001 Issue 1 App 3B-3
2.4 Monitoring Procedures

The characteristics of the radiations emitted by LSA material are such that correct use of
the detector is essential to obtain a meaningful result. This is particularly important when
attempting to decide whether a piece of equipment is contaminated.
An accurate assessment of contamination is dependent on the following:
(1) The instrument must be suitably calibrated for LSA material and
operating correctly.
(2) The protective cover must be removed from the detection probe.
(3) The sensitive face of the detector should be angled towards and placed as close as
possible to the surface being monitored. Measurements shall be made with the
sensitive face of the detector about 0.5cm from the surface being monitored.
Uncontrolled
(4) Monitoring shall be carried out by moving the detector over the surface at a
slow rate, giving the detector time to ‘see’ any emitted radiation.
(5) The background count rate shall be subtracted from the measured count
rate before comparing any reading with the calibration figures to obtain a
contamination level.
(6) The DP2 probe placed across the end of a tubular or equipment aperture may not
detect low levels of contamination inside. A smaller diameter, slightly less efficient
detector correctly placed inside will give a more accurate assessment of the
contamination present.
Radiation Monitoring Instruments Part 2

App 3B-4 November 2001 Issue 1
Appendix 3C
Packing and Labelling of Consignments of
Equipment Contaminated with LSA Material
for Transportation
Paragraph Page
1 General 3C-1
2 General Requirements of Strong

Uncontrolled
Industrial Packages 3C-1
3 Labelling 3C-1
3.1 Number of Labels to be Affixed to Packages etc 3C-2
3.2 Contents 3C-4
3.3 Transport Index 3C-4
4 Surface Contamination 3C-5
5 Additional Requirements for other than

‘Exempt’ Packages for Carriage by Road 3C-5
6 Package Requirements for LSA Samples

Sent by Helicopter 3C-8
7 Transportation Documentation 3C-8

7.1 Shipper’s Certificate for Radioactive Material 3C-9
7.2 United Nations Numbers 3C-10
Part 2 Packing and Labelling of Consignments of Equipment Contaminated

November 2001 Issue 1 with LSA Material for Transportation App 3C-i/ii
1 General
The basis for the identification of equipment contaminated with Low Specific Activity
(LSA) material is the radiation monitoring results for surface contamination and/or
dose rate, since in operational activities it is unrealistic to ensure sampling and analysis
of each item of equipment removed from service.
Where any monitor reading, sustainable above the normal background, is obtained this
is taken to indicate the presence of radioactive contamination. At this stage, if the item
is to be despatched from the Installation, it must be adequately packaged and
correctly labelled and documented to meet the requirements of the appropriate
transportation legislation.
Items contaminated with radioactive LSA material must be packed such that no leakage
of the material will occur in transit, eg as a strong industrial package.
Uncontrolled
Items may be carried or transported as:

• Individual package, ie a valve or a pump
• As a group of individual packages within a container, constituting an overpack
• As a full load, eg in a dedicated freight container
2 General Requirements of Strong Industrial Packages

LSA contaminated equipment will generally be transported as a strong industrial package
and must:
• Be designed so that it can be easily handled and can be secured during transportation
• If 10kg or more and up to 50kg, be provided with a means of manual handling
• If in excess of 25kg, be designed to enable its safe handling by mechanical means
• Be designed to avoid, as far as practicable, the collection and retention of water
• Have outer surfaces such that they can be easily decontaminated
• Be designed to withstand the normal conditions of transport
3 Labelling
The external surfaces of all ‘non-exempt’ or ‘non-excepted’ packages, overpacks, freight
containers and tubing containing LSA material must carry distinctive labels to indicate
that they contain radioactive material. Different categories of package/container are
identified by the colour of the label and the number of red stripes printed on it (refer to
Paragraph 3.1).
The shipper must describe the contents of the package etc by completing the
appropriate parts of the label.

November 2001 Issue 1 with LSA Material for Transportation App 3C-1
Packages, overpacks or freight containers must be in one of three categories depending

on the maximum dose rate on the external surface of the package etc and its Transport
Index (TI) (refer to Paragraph 3.3):
• Category I – White
A package is in Category I – White – when the radiation dose rate at any point on the
external surface of the package during transportation does not exceed 5µSvh-1.
A freight container is in Category I – White – when it carries packages of radioactive
materials, none of which is in a category higher than ‘Category I – White’.
Such packages and freight containers require to be marked with white labels with one
red stripe.
• Category II – Yellow
Uncontrolled
A package is in Category II – Yellow – when the radiation dose rate at any point on the
external surface of the package during transportation does not exceed 500µSvh-1 and
the TI at any time during transportation does not exceed 1.0.
A freight container is in Category II – Yellow – when the TI at any time during
transportation does not exceed 1.0.
Such packages and freight containers require to be marked with yellow labels with
two red stripes.
• Category III – Yellow
A package is in Category III – Yellow – when the radiation dose rate at any point on
the external surface of the package during transportation does not exceed 2mSvh-1
and the TI does not exceed 10.
A freight container is in Category III – Yellow – when the TI exceeds 1.0.
Such packages and freight containers require to be marked with yellow labels with
three red stripes.
Equipment contaminated with LSA material will invariably be Category III – White or
on occasion Category II – Yellow.
3.1 Number of Labels to be Affixed to Packages etc

• Packages and overpacks – if rigid, affix two labels to opposite sides. If not rigid or
irregular in shape, one label is acceptable if it is attached to a strong durable tag
• Freight containers – affix one label on each of the four sides
• Tubing – affix LSA warning tape to each tubular and two labels to the lifting strops of
the bundle of tubing. If tubing is individually consigned, affix two labels on opposite
sides of each tubular
Packing and Labelling of Consignments of Equipment Contaminated Part 2

App 3C-2 with LSA Material for Transportation November 2001 Issue 1
7c
Category White I
All White Label
RADIOACTIVE
CONTENTS .........................................
7b
Uncontrolled
ACTIVITY .................................... Category Yellow II

Label
7a RADIOACTIVE
CONTENTS .........................................
ACTIVITY ....................................
TRANSPORT INDEX
RADIOACTIVE
CONTENTS .........................................
ACTIVITY .................................... Category Yellow III
Label
TRANSPORT INDEX
7 UKCSSOP004_010.ai

3.2 Contents
Insert the name of the principal radionuclide, eg radium 226. In the case of low specific
activity material, it is sufficient to write LSA.
The activity of the contents of the package etc shall be inserted. For items contaminated
with LSA material, a best estimate of activity should be given by using an estimated
value for the specific activity of the material, unless an analysis figure is available,
and multiplying it by the estimated weight of LSA material in the package.
Example:
Estimated specific activity of scale = 20Bqg-1 Ra 226
Estimated weight of scale = 50kg
Activity contained within package = 20 x 50MBq
Uncontrolled
1000
= 1 MBq Ra 226
If the specific activity is not known and there is not enough time to wait for a sample to
be sent and analysed, the measured contamination level can be used to estimate the
activity content as follows:
Example:
Maximum surface contamination
-2
level measured = 10Bq/cm Ra 226
2 4 -2
Total contaminated area of item = 2.5m (2.5 x 10 cm )
4
Activity of contents of package = 10 x 2.5 x 10
= 250KBq Ra 226
3.3 Transport Index

Note: This applies to Category II and III Yellow packages only.
-1
The TI of a package is the maximum dose rate in µSvh as measured at 1 metre from the
external surface of the package or overpack, divided by 10. It is a number with no units
and should be quoted to the first decimal place only. The TI must be entered on
the label. This gives the recipient an immediate indication of the external dose rate from
the package.
Example:
Maximum dose rate at 1 metre from external surface of package – 14.2µSvh-1.
Transport Index = 1.4.
The TI of a freight container, which contains a number of packages or overpacks, can be
assessed either by summing the TIs of the individual packages and overpacks it
contains, or by determining a TI for the container by measuring the maximum dose rate
at 1 metre from the external surface of the container in µSvh-1, dividing this dose rate
by 10 and multiplying the resultant figure by a factor appropriate to the cross-sectional
area of the container. The TI, so calculated, shall be written on all four labels, one for
each side of the freight container.

4 Surface Contamination
The non-fixed contamination of any external surface of a package, overpack or freight
container must be kept as low as practicable and under normal conditions of transport
must not exceed the levels stated below.
The level of non-fixed contamination may be determined by wiping an area of 300cm2
of the surface concerned by hand with a dry filter paper or cotton wool and estimating
the activity transferred to the wipe. The surface contamination is obtained by multiplying
the activity measured on the wipe by 10 (10% as removable contamination) and dividing
by the area wiped (300cm2).
Example:
Count rate measured from cotton wool by DP2 probe = 20cps.
From probe calibration certificate 20cps = 4Bqcm-2 Ra 226.
Uncontrolled
Area of DP2 probe = 50cm2.

Activity transferred to cotton wool:
By wiping 300cm2 = 4 x 50 = 200Bq
Total activity = 200 x 10Bq
Surface contamination = 200 x 10Bqcm-2
300
-2
= 7Bqcm Ra 226
The maximum permissible levels of non-fixed (loose) radioactive contamination are

as follows:
• Beta/gamma emitters and low toxicity alpha: 4Bqcm
-2
• All other alpha emitters: 0.4Bqcm-2

Note: (1) The above levels are permissible when averaged over any area of 300cm2
of any part of the surface.
(2) Low toxicity alpha emitters include natural uranium; natural thorium,
uranium 235, uranium 238, thorium 232, thorium 228 and thorium 230
when contained in ores or physical concentrates and radionuclides with a
half-life of less than 10 days.
5 Additional Requirements for other than ‘Exempt’

Packages for Carriage by Road
No person other than the driver may be carried in the vehicle unless the carrier’s
permission is given.
When radioactive materials are being carried in his vehicle, the carrier must not permit
anyone to travel in it elsewhere than in the cab beside the driver.

The carrier must not permit anyone under 18 years of age to travel in his vehicle when it
carries radioactive materials unless white label packages only are carried. Anyone under
18 years of age must leave the driving cab if there is any risk at any time of the radiation
there exceeding 20µSvh-1.
A fireproof notice of the form illustrated below must be carried in the cab of the vehicle.
The notice must be white, not less than 12cm square and have black lettering. The word
‘radioactive’ must be in letters of not less than 5mm high.
The notice must be firmly fixed in a position visible to the driver and must only be
displayed when the vehicle is carrying radioactive materials.
This vehicle is carrying
Uncontrolled
RADIOACTIVE
MATERIALS
In case of accident, get in touch at once with
THE POLICE
and
(Particulars of owner/operator of vehicle)
UKCSSOP004_011.ai

A vehicle placard in the form illustrated below must be displayed on each side and the
rear of the vehicle.
Uncontrolled
RADIOACTIVE
Minimum dimension – 25cm UKCSSOP004_012.ai
Note: When larger dimensions than the minimum dimensions shown are used,
the relative proportions must be maintained.
When a freight container is carried on a vehicle which has no side or rear wall,
the vehicle placards must be fixed to each of the four lateral walls of the
freight container.

6 Package Requirements for LSA Samples Sent

by Helicopter
The International Air Transport Association (IATA) Dangerous Goods Regulations 1993
permit up to 20MBq of material incorporating radium 226 and 40MBq radium 228 to be
transported as an ‘excepted package’.
The requirements for ‘excepted’ packages are as follows:
• The radiation level at any point on the external surface of the package shall not
exceed 5µSvh-1
• Non-fixed radioactive contamination on any external surface of the package shall not
exceed 0.4Bqcm-2
• Materials shall be packaged such that, during normal conditions of transport, there
Uncontrolled
can be no leakage of radioactive material from the package
• Packages should be described on the air waybill as ‘Radioactive Material Excepted
Package – Limited Quantity of Material’
• The packaging should bear the marking ‘Radioactive’ inside the package so that
warning of the radioactive material is visible on opening the package
• There is no requirement for a ‘Shipper’s Certificate for Radioactive Materials’
7 Transportation Documentation
The person who offers dangerous goods (other than excepted packages) for transport
must provide to the transporter, with two copies of a transport document
(Shipper’s Certificate for Radioactive Materials) completed and signed. The document
must provide the information shown in the example in Paragraph 7.1.
Where the consignment is to be transported by road, the BP Shipper’s Certificate must
be appended with a statement on the following terms:
‘This is to certify that the above named goods are properly described and are
packed and marked in accordance with the requirements of The Radioactive Material
(Road Transport) (Great Britain) Regulations 1996, or of the International Regulations and
are in a proper condition for transport.’
On consignments from offshore Installations, this shall be done at the supply base prior
to despatch by road.

7.1 Shipper’s Certificate for Radioactive Material
SPECIMEN

Uncontrolled
This is to certify that the goods listed below are properly described and are packed and marked in accordance with
the applicable provisions of the appropriate transport requirements.
Description of Material
Isotope RADIUM 226 AND DAUGHTERS
Radioactive Substance CLASS-7
Schedule No SCHEDULE-8 (SCO)
Physical Form SOLID MATERIAL
UN Number 2913 – SURFACE CONTAMINATED OBJECT (SCO-I)
Activity of Contents (Bq) 30MBq
Package Type STRONG INDUSTRIAL
Category I – WHITE
Transport Index N/A
Surface Dose Rate of 1.0

Package (µSvh-1)
Shipper: ACME SHIPPING LINE, Shipped by: BP,

ABERDEEN FARBURN INDUSTRIAL ESTATE,
DYCE, ABERDEEN
XXXXX PLATFORM
Signed ............................................................................... Date ..........................................................................
UKCSSOP004_013.ai

7.2 United Nations Numbers
EXCERPT FROM LIST OF UNITED NATIONS NUMBERS,

PROPER SHIPPING NAME AND
DESCRIPTION AND SUBSIDIARY RISKS
Uncontrolled
Number Name and Description Subsidary Risks
2910 Radioactive Material, Excepted Package:
• Instruments or Articles
• Limited Quantity of Material
– Samples**
• Articles Manufactured from Natural Uranium or
Depleted Uranium or Natural Thorium
• Empty Package
2912 Radioactive Material, Low Specific Activity (LSA), NOS*
2913 Radioactive Material, Surface Contaminated Objects

(SCO)
• LSA Contaminated Equipment**
2918 Radioactive Material, Fissile, NOS*
2974 Radioactive Material, Special Form, NOS* Liable to spontaneous

combustion
2975 Thorium Metal, Pyrophoric
Oxidising substance
2976 Thorium Nitrate, Solid Corrosive
2977 Uranium Hexafloride, Fissile containing more than

1.0% uranium 235 Corrosive
2978 Uranium Hexafloride, Fissile excepted or non-fissile Liable to spontaneous

combustion
2979 Uranium Metal, Pyrophoric
Corrosive
2980 Uranyl Nitrate Hexahydrate Solution Oxidising substance
2981 Uranyl Nitrate, Solid
2982 Radioactive Material, NOS*
* NOS – Not Otherwise Specified

** Application
UKCSSOP004_014.ai

Appendix 3D
Installation Authorisation Certificates
Copies of the original certificates relating to each Installation are retained by the Radiation
Protection Adviser (RPA).
Originals are held on each Installation and shall be displayed in a place where they can be
conveniently read by anyone involved in work with Low Specific Activity (LSA) material or
whose work may be affected by the presence of the material.
Holders responsible for this document should insert copies of authorisations relevant to their
particular Installation directly after this Appendix.
Uncontrolled
Part 2 Installation Authorisation Certificates

November 2001 Issue 1 App 3D-1/2
Section 4
Documentation
Paragraph Page

Contaminated Equipment 4-1
2 Offshore Disposal to Sea of LSA Material 4-2
3 Analysis, Transport and Disposal (ATD) Form 4-3

Uncontrolled
4 Radiological Exposure of a Non-classified Worker 4-4
5 Onsite Radiological Exposure Record 4-5
6 Responsibility for Radiation Controlled Areas 4-6
7 Shipping Instruction 4-7
8 Shipper’s Certificate for Radioactive Materials 4-8
9 Procedure for the Management and

Disposal of Radioactive Waste 4-9
9.1 Introduction 4-9
9.2 LSA Scale/Naturally Occurring
Radioactive Material (NORM) 4-10
9.3 Offshore Disposal to Sea 4-10
9.4 Sending Contaminated Equipment to the Beach 4-13
9.5 Disposal of Radiotracers 4-13
9.6 Storage/Security 4-14
Uncontrolled
1
Part 2
Record of Low Specific Activity Radioactive Scale Onshore Disposal
Platform: .......................................................................................................... Year: Page: .............
Carried
Forward
SCALE DISPOSAL REPORT

Source of LSA
Scale (State *Total Specific *Total
Equipment No, Date Scale Weight Specific Activity Radium 226 Activity Actinium 228 **Total
Line No, Notification Manifest ATD Cleaning Date Report No Disposed Radium 226 Activity Actinium 228 Activity Activity

Vessel etc) Fax Sent Number Number Contractor Disposed Cert No (kg) (Bqg-1) (MBq) (Bqg-1) (MBq) (MBq) Comments Initials
Cumulative Cumulative Cumulative

weight = activity = activity =

Contaminated Equipment




Onshore Disposal of Low Specific Activity (LSA)
* Total Radium 226 Activity = Specific Activity Radium 226 x Weight Discharged (kg) + 1000 = MBq (similarly for Actinium 228).
** Total Activity = 6 x Total Radium 226 Activity + 8 x Total Actinium 228 Activity = MBq.
UKCSSOP004_015.doc
4-1
Documentation
UKCS-SOP-004
2
4-2
Record of Low Specific Activity Radioactive Scale Offshore Disposal
Documentation
UKCS-SOP-004
Platform: .......................................................................................................... Year: Page: .............
Carried
Forward
Source of LSA
Scale (State *Total Specific *Total
Equipment No, Date Weight Specific Activity Radium 226 Activity Actinium 228 **Total
Line No, ATD/Job Notification Date Discharged Radium 226 Activity Actinium 228 Activity Activity
Vessel etc) Number Fax Sent Disposed (kg) (Bqg-1) (MBq) (Bqg-1) (MBq) (MBq) Comments Initials




Offshore Disposal to Sea of LSA Material


* Total Radium 226 Activity = Specific Activity Radium 226 x Weight Discharged (kg) + 1000 = MBq (similarly for Actinium 228).
** Total Activity = 6 x Total Radium 226 Activity + 8 x Total Actinium 228 Activity = MBq.
UKCSSOP004_016.doc

Part 2
Uncontrolled
3 Analysis, Transport and Disposal (ATD) Form
Job No: ........................................
ANALYSIS, TRANSPORT AND DISPOSAL

OF LSA CONTAMINATED EQUIPMENT
(1) SAMPLES FOR ANALYSIS Date: ...............................
Quantity ............................................. Sample ID Nos .................................. Sent for Analysis ..........................................
Taken from ........................................ .................................. Telex to NDP ...............................................
.................................. Signature of RPS ..........................................
(2) TRANSPORT
Uncontrolled
Description of Equipment ........................................................................................................................................................
Packing: Container No(s) .......................................................... Others (Qty and Type)

..........................................................
.......................................................... ..........................................................
Identification No(s) ........................................... LSA .............................. to ........................... LSA ...........................
Vessel Name .......................................................... Manifest No

.................................................... Date ...........................
Vessel ETD ........................................... hrs ETA .............................. hrs at .............................................(Port)
Estimated weight of scale adhering to equipment ................................................................................................................g
Details telexed to NDP and supply base

......................................................................................... Date ..............................
(3) DISPOSED TO SEA
Estimated weight of scale disposed/to be disposed to sea ................................................................................................... g
(4) SUPPLY BASE
Collection D elivery
.................................................. ..................................................
Signature of Contractor Uplifting Signature of Consignee
....................................................................................... .......................................................................
Company Company
(5) DISPOSALS
Disposal Contractor informed .......................................................................................................... Date ...........................
Estimated Wt x Specific Activity = Total Activity
To sea ............................................... g ........................................... Bqg-1 ................................................................Bq

(Estimated by RPS at job completion)
To Contractor .......................................... g ........................................... Bqg-1 .......................................................... Bq
Total .................................................... Bq
Signed ........................................................... NDP
COPY 4 Forwarded by supply base after completion of Part 4. NDP completes and returns record.
UKCSSOP004_017.doc
4 Radiological Exposure of a Non-classified Worker

Name ..............................................................................................
Address ..........................................................................................
..........................................................................................
..........................................................................................
Company
.........................................................................................
Company No RADIOLOGICAL EXPOSURE OF A
....................................................................................
NON-CLASSIFIED WORKER
Calendar Year ..................................................................................
Cumulative Surface Personal Contamination
Nett Exposure Contamin Dose Rate
Date Exposure Time Work Area Bqcm-2 µSv -1 Before After RPS Sign
Uncontrolled
Brt Fwd
c.fwd
Responsible Person Sign .........................................................................................
Date .....................................................................................................................
UKCSSOP004_018.doc
5 Onsite Radiological Exposure Record
ONSITE RADIOLOGICAL EXPOSURE RECORD

(sample page from entry point logbook)
DATE
(1)
DAY/NIGHT WORK AREA PERMIT NOs
(2) (3) (4)
Personal Contam Max Surface
Max Dose Contamin Entry Control
Print Name/No Time In Time Out Before After Rate µSv-1 Bqcm-2 Signature
Uncontrolled
Contamination Meter Serial No ....................................................... Calibration

.................. Bqcm-2 To ........................................ CPS
Probe Serial No ............................................................................... Supervised .............................. To ........................................ CPS
Dose Meter Serial No ...................................................................... Controlled .............................. To ........................................ CPS
1 Delete as applicable.
2 Personal contamination – results of measurements before and after washdown of personnel in counts per second.
3 Maximum dose rate (µSv-1) of area at start of work.
4 Maximum surface contamination measurement (Bqcm-2) at start of work.
UKCSSOP004_019.doc
6 Responsibility for Radiation Controlled Areas
Responsibility for Radiation Controlled Areas
The lonising Radiations Regulations 1999
Uncontrolled
The above legislation requires the designation of Radiation Controlled Areas for work with
radioactive materials when specified levels of dose exposure and/or surface and airborne
contamination are exceeded.
The work described below which is covered by these regulations has been handed over to
the named contractor for the purposes of Radiological Protection.
All other responsibilities, both legal and contractual, for the work remain with BP.
Installation: ...........................................................................................
Contractor: ...........................................................................................
Work Location: ...........................................................................................
Description of Work: ...........................................................................................
.................................................................................................................................................
.................................................................................................................................................
Commencement: Date .............................. Time

............................
Completion: Date .............................. Time

............................
For Contractor (RPS): ..............................................................................

signed
..............................................................................
print
For BP (RPS): ..............................................................................

signed
..............................................................................
print
Date: ..............................................................................
UKCSSOP004_020.doc
Uncontrolled
7
Part 2
SHIPPING INSTRUCTION SERIAL NO
FROM COLLECT FROM DELIVER TO

ORIGINATOR
TO TRANSPORTATION SECTION
DATE / /
SERIAL NUMBER MUST BE QUOTED ON ALL QUERIES

Item Number Type of Reference Number Description of Goods KILOS Offs hore Customs
and Pkgs Consignee Status
Shipping Instruction
SPECIAL INSTRUCTION C/S NO DUNDEE/3/74 DETAILS OF TRANSPORTATION

RGR No DUNDEE/2/78
MODE OF TRANSPORT VOY NO SIGNATURE
VAT NO 365678995
DATE / /
DISTRIBUTION: WHITE – CONSIGNEE : BLUE – DESPATCH : GREEN – ORIGINATOR
UKCSSOP004_021.doc
4-7
Documentation
UKCS-SOP-004
8 Shipper’s Certificate for Radioactive Materials
Uncontrolled
This is to certify that the goods listed below are properly described and are packed and marked in accordance with the
applicable provisions of the appropriate transport requirements.
Isotope
Radioactive Substance
Schedule No
Physical Form
UN Number
Activity of Contents (Bq)
Package Type
Category
Transport Index
Surface Dose rate of
Package micro Svh-1
Shipper: Shipped by:
Signed:.................................................................................... Date: ...................................................................................
UKCSSOP004_022.doc
9 Procedure for the Management and Disposal of

Radioactive Waste
9.1 Introduction
This document, which deals with the disposal of radioactive material from the
Installation/site, is, in the main, a stand-alone document which has been produced to
comply with the requirements of the Authorisation to Accumulate and Dispose of
Radioactive Waste. The authorisation is issued and policed by the Scottish Environment
Protection Agency (SEPA), and is included in the local rules for completeness.
All future authorisations for the accumulation and disposal of radioactive material issued
under the Radioactive Substances Act 1993, will require the nomination of suitably
trained site personnel to be responsible for the management of radioactive waste onsite.
Uncontrolled
The site Radiation Protection Supervisor (RPS) will assume this responsibility. As the
new authorisations are issued, or sooner, if deemed appropriate by the Company,
individual sites will supply SEPA with the required names.
9.1.1 Smoke Detectors

Most Installations carry spare smoke detectors to be used in the event of an
installed detector failing. Under the Radioactive Substances Act 1993 (RSA93) all
detectors containing radioactive material in excess of 40 Kilobecquerels, which are not
installed (ie kept in storage) must be registered on the Company’s Certificate of
Registration, issued under RSA93.
Those detectors containing radioactive material less than 40 Kilobecquerels do not
require to be registered.
Accounting
All smoke detectors in storage must be accounted for. A record will be kept to
accurately reflect he number of detectors in storage at any given time.
Disposal
Smoke detectors unfit for purpose or surplus to requirements will be returned to the
manufacturer as soon as practicably possible. The manufacturers will be informed of
their return in advance of their arrival. The Radiation Protection Adviser (RPA) will be
consulted regarding the number of detectors placed in each package.
Smoke detectors unfit for purpose may be regarded as waste and will be returned to the
manufacturer at the earliest opportunity (within 12 weeks).
9.2 LSA Scale/Naturally Occurring Radioactive Material (NORM)

LAS or NORM is deposited in certain parts of the plant as part of the oil recovery
process. It may take a number of years for this to appear on a new Installation and the
problem, once identified, may reduce over the lifetime of the Installation. It is impossible
to predict where the material will appear, but we can predict which parts of the
Installation are likely to be affected. Typical areas are:
• Produced water systems
• Dump hoses
• Production tubing
• Separators
• Dehydrators and associated pipework
Uncontrolled
• Pumps valves
The Installation, having identified the problem, or potential problem, will have applied
to SEPA through the Radiation Protection Adviser (Synetix) for an authorisation to
accumulate and dispose of this radioactive material.
When received, the authorisation must be posted on the Installation.
The Certificate of Authorisation will specify an activity limit on the radioactive material
disposed of to sea in any 1 year, generally 5 or 10 Gigabecquerels. The certificate will
also specify which shore bases can accept equipment contaminated with radioactive
material, eg Scotoil, Score Europe.
Note: Loose radioactive material is seen as waste and must not be transported to the
beach, without prior authorisation from the RPS and Offshore Installation
Manager (OIM).
Samples of radioactive material can be sent to the beach for analysis and are not
classified as waste.
9.3 Offshore Disposal to Sea

In general, offshore cleaning is carried out by contractors, who estimate weights,
take samples and, subsequent to maceration, dispose of the material to sea.
The operating Company remains responsible for the compliance with the requirements
of the authorisation. To this end, the following procedures will be followed to
ensure compliance.
(1) The Installation RPS will, with the assistance of the contractor RPS, estimate the
total weight likely to be disposed of to sea and using previous sample analysis,
where possible, estimate the total activity. Any previous disposal records will be
checked and the RPS will assess whether or not the authorisation limit is likely to
be exceeded.
If this is a probability, the RPS will contact the RPA and ensure that no radioactive
material (above the exemption limit) is sent to sea.
(2) On breaking containment the nature of the radioactive material will be identified
and a representative sample of each taken for analysis, eg sand, sludge, hard scale
or wax.
If only one form of material is present only one sample will be required. The RPS
will ensure that the samples are representative of the radioactive material present.
(3) These samples will be sent to Synetix for radiochemical analysis.
(4) The weight of the material removed will be assessed by either:
(a) Calculation
Calculating the volume of material and using figure for density calculate
the weights.
(b) Physical Measurement
Uncontrolled
Weighing and recording a percentage of the material for disposal and

calculating the totals weights.
These mean weights will be recorded and, using the analysis figures, the total
activities calculated.
The definition of radioactive material, from Schedule 1 of the Radioactive
Substances Act 1993 for solid material is:
• Radium 226: 0.37Bq/g
• Lead: 0.74Bq/g
The Radioactive Substances (Phosphatic Substances Rare Earths etc) Exemption
Order 1962 sets an exemption limit for LSA/NORM of 14.8Bq/g.
Note: Material with a specific activity of less than 14.8Bq/g may be disposed of
without authorisation.
If analysis shows radium 226 figure x 2 plus the actinium 228 figure x 1.7 is less
than 14.8Bq/g, the material is exempt.
If the above calculation indicates that the material is not exempt the total activity
must be calculated.
Total Activity = Radium 226 x 6 plus actinium 228 x 8Bq/g
(5) The above calculation will be used for each form of radioactive material and the
totals recorded (refer to the following example).
(6) A running total for all disposals to sea will be recorded in the LSA disposal records.
(7) The RPS will ensure that all material disposed of to sea is macerated to levels
required by the certificate of authorisation, by confirming the presence of a suitable
filter in the outlet of the macerator.
(8) Results of the radiochemical analysis will be retained to confirm the activities
disposed of, and, where appropriate, the reasoning behind defining material
as exempt.
9.3.1 Example of Total Activity Disposed of to Sea

(1) Sand
Estimated weight 10,000kg
Results of radiochemical analysis:
• Radium 226: 1.0Bq/g
• Actinium 228: 0.5Bq/g
Ra 226 x 2 plus Ac 228 x 1.7 = 3Bq/g – less than 14.8Bq/g therefore
EXEMPT: no requirement to include weight in disposal figures
(2) Sludge
Estimated weight 3000kg
Uncontrolled
• Radium 226: 10Bq/g
• Actinium 228: 5Bq/g
Ra 226 x 2 plus Ac 228 x 1.7 = 30Bq/g – greater than 14.8Bq/g therefore
NOT EXEMPT
Total activty: Radium 226 x 6 plus actinium 228 x 810 x 6 + 5 x 8 = 100Bq/g
Therefore, for 3000kg: 100 x 1000 x 3000 = 300 Megabecquerels
(3) Hard Scale
Estimated weight 5000kg
• Radium 226: 25Bq/g
• Actinium 228: 12Bq/g
Ra 226 x 2 plus Ac 228 x 1.7 = 70Bq/g – greater than 14.8B/g therefore
NOT EXEMPT
Total activity: Radium 226 x 6 plus actinium 228 x 8 = 246Bq/g
Therefore, for 5000kg: 246 x 1000 x 5000 = 1230 Megabecquerels
Total disposed: 1230MBq + 300MBq = 1530MBq or 1.53 Gigabecquerels
9.4 Sending Contaminated Equipment to the Beach

As previously stated the authorisation allows the Installation to send contaminated
equipment to specified companies on the beach for cleaning.
Note: Contaminated equipment does not inlude loose radioactive material.
The Installation RPS will ensure that:
(1) The equipment has been monitored to confirm the contamination levels, these
results will be recorded.
(2) The contaminated equipment will be suitably bagged and labelled for
onward shipment.
(3) The onshore cleaning company will supply the Installation with a record of the
weight of material cleaned and the radiochemical analysis of that material.
Uncontrolled
(4) The RPS will keep a record of the information supplied by the onshore
cleaning companies.
9.5 Disposal of Radiotracers

Radiotracers are commonly used to assess residence times in vessels, flowrates,
gas carry-over and water carry-under. The Installation must have an authorisation to
dispose of the radioactive materials and activities used. The radiotracers used in these
trials have a short half-life. Therefore it is resonable to assume that all radioactive
material will be disposed of to sea, or to flare, in a short period of time.
Other radiotracers may be used in reservoir studies. These have a long half-life and may
not be released into the environment for a considerable period of time (12 months or
longer). Installations carry out appropriate regular sampling of the produced water,
hydrocarbons or other tracer pathways. The frequency of the sampling programme is
determined by the Operator, in conjunction with the contractor.
To ensure compliance with the authorisation:
(1) The Installation RPS will liaise with the contractor carrying out the work, to ensure
that the contractor has a valid certificate of registration and that the Installation has
a valid certificate of authorisation.
(2) The Installation RPS will record the type of radiotracer used and the actual activity
disposed of (this may not always be the amount indicated on the contractor’s
registration, when half-life etc is taken into account).
(3) For reservoir studies using radioactive material, the RPS will ensure the agreed
sampling regime is adhered to. Samples will be sent to Synetix for analysis.
(4) For reservoir studies using radioactive material, the Installation will have available
produced water figures. At the end of a specificed number of weeks, using the
produced water figures and the sample analysis results, the RPS will estimate and
record the activity of radioactive material released into the environment.
The RPS will ensure that records, for all disposals of radioactive material,
are retained on the Installation or are available from the onshore cleaning company.
These will be made available to the RPA, for review and on-pass to SEPA,
by the second week in February.
9.6 Storage/Security
The authorisation for the accumulation and disposal of LSA waste requires the
disposal to take place as soon as reasonably practicable. If at all possible the
material should be macerated and disposed of to sea and not stored on the Installation.
Uncontrolled
However, should there be a requirement to store bulk material, prior to disposal,
the following will be carried out by the RPS.
(1) The material will be stored in suitable containers (drums) labelled to indicate the
presence of ionising radiations.
(2) The radiation dose rates around the drums will be recorded and the area
demarcated. The area will be designated a controlled or supervised area,
depending on the results of the dose rate monitoring, and appropriate warning
signs posted accordingly.
(3) The integrity of the storage containers and, if necessary, the storage area will be
confirmed daily and a suitable record kept.
(4) Contaminated equipment will be suitably bagged and tagged to prevent the
possible spread of contamination and to indicate the presence of ionising
radiations. These items will be stored in a designated area and checked daily while
awaiting transportation to the beach.
Note: It is important that contaminated equipment and waste, are seen to be
managed and that the possibility of sending waste to the beach,
or contaminated equipment to an unauthorised site, is further reduced.
We have no authorisation to send radioactive waste onshore for disposal.
If in any doubt contact the RPA.
Addendum 1
References
Paragraph Page
1 External References 1
1.1 Acts 1
1.2 Statutory Regulations, Notices and
Approved Codes of Practice (ACoPs) 1
1.3 Codes and Standards 2
Uncontrolled
1.4 Guidance 2
2 BP References 2
Part 2 References
November 2001 Issue 1 Add 1-i/ii
1 External References
1.1 Acts
(1) Health and Safety at Work etc Act 1974.
(2) The Radioactive Substances Act 1993.
(3) The Environmental Protection Act 1990.
1.2 Statutory Regulations, Notices and Approved Codes of

Practice (ACoPs)
(1) The Ionising Radiations Regulations 1999, SI 1999/No 3232.
(2) The Management of Health and Safety at Work Regulations 1999.
Uncontrolled
(3) The Ionising Radiations (Outside Workers) Regulations 1993, SI 1993/No 2379.
(4) The Radioactive Material (Road Transport) (Great Britain) Regulations 1996.
(5) The Offshore Installations (Operational Safety, Health and Welfare) Regulations
1976, SI 1976/No 1019.
(6) The Offshore Installations (Emergency Procedures) Regulations 1976, SI 1976/
No 1542.
(7) The Radioactive Substances (Smoke Detectors) Exemption Order 1980, SI 1980/
No 953.
(8) The Radioactive Substances (Smoke Detectors) Exemption (Scotland) Order 1980,
SI 1980/No 1599.
(9) The Radioactive Substances (Smoke Detectors) Exemption (Amendment) Order
1991, SI 1991/No 477.
(10) The Radioactive Substances (Luminous Articles) Exemption Order 1985, SI 1985/
No 1048.
(11) The Radioactive Substances (Testing Instruments) Exemption Order 1985, SI 1985/
No 1049.
(12) The Radioactive Substances (Phosphatic Substances, Rare Earths etc) Exemption
Order 1962, SI 1962/No 2769.
(13) The Radioactive Substances (Gaseous Tritium Light Devices) Exemption Order
1985, SI 1985/No 1047.
(14) The Merchant Shipping (Dangerous Goods) Regulations 1981, SI 1981/No 1747.
(15) The Air Navigation (Dangerous Goods) Regulations 1985, SI 1985/No 1939.
(16) The Air Navigation (Dangerous Goods) Regulations (Amendment) 1986, SI 1986/
No 2129.
(17) Dangerous Substances in Harbour Areas Regulations 1987, SI 1987/No 37.
Part 2 References
November 2001 Issue 1 Add 1-1
1.3 Codes and Standards

(1) Code of Practice for Site Radiography.
(2) Code of Practice for Carriage of Radioactive Material Through Ports.
(3) Safety Standards No 6 – Regulations for the Safe Transport of Radioactive Material
1985 Edition (as amended 1990). International Atomic Energy Agency (IAEA).
1.4 Guidance
(1) Radiation Safety in Underwater Radiography, GS41. Health and Safety Executive.
(2) Respiratory Protective Equipment for Use against Airborne Radioactivity, EH53.
Health and Safety Executive.
(3) A Framework for the Restriction of Occupational Exposure to Ionising Radiation
Uncontrolled
(HS(G)91). Health and Safety Executive.
(4) The Examination and Testing and Calibration of Portable Radiation Instruments.
2 BP References
(1) BP ‘Getting HSE Right’.
(2) BP HSE Practices:
No 2 Accident Incident Reporting
No 3 Permit to Work System
References Part 2
Add 1-2 November 2001 Issue 1
Addendum 2
Procedure in the Event of a
Paragraph Page
1 Legal Framework 2-1
2 Government Agencies 2-1

Uncontrolled
3 Outline Procedure in the Event of a

Lost Radioactive Source in a Well 2-1
3.1 Formal Submission Guidelines 2-2
4 Contact List 2-4
5 Example A Generic Risk Assessment Format 2-5
6 Example B Generic Risk Assessment Format 2-8
Procedure in the Event of a Lost Radioactive Source in a Well

March 2002 Issue 1/AM01 Add 2-i/ii
The objective of this addendum is to provide outline guidance within BP UK drilling and wells
operations on the process to follow in the event of a lost radioactive source in a well.
1 Legal Framework
• Radioactive Substances Act 1993 (RSA ‘93)
• Ionising Radiation Regulations (IRR) 1999
2 Government Agencies
In Scotland the Scottish Environmental Protection Agency (SEPA) is responsible for
Uncontrolled
regulating disposal of radioactive waste from nuclear sites and other premises such as
industrial, hospital and research premises under the Radioactive Substances Act 1993
(RSA ‘93). SEPA also regulates the keeping and use of radioactive material.
In England, the Environment Agency (EA) performs the same role.
3 Outline Procedure in the Event of a

The basic scenario being described is for a well with a stuck wireline logging tool, but
would be applicable for a Logging Whilst Drilling (LWD) tool. In this addendum the
references are to SEPA but it is believed a similar procedure is used by the EA. The
procedure only reflects offshore operations in the UK; there may be other requirements
for land operations in the UK and for other North Sea areas.
When the source becomes stuck, the owner of the source (normally the logging
company) should immediately inform SEPA.
Note: This notification should normally come from the registered user of the source
who has obligations under the terms of their registration. The initial notification
should normally be made by telephone to SEPA on 01224 248338.
SEPA will open an event log and acknowledge this notification, and either ask for further
information (source details, location etc) or will ask to be kept informed.
When the source is recovered, the owner should inform SEPA as soon as possible;
SEPA will close the event log when it is confirmed that the source is not damaged.
It is recommended that BP sends confirmation of these notifications, referencing the
logging company correspondence.
If, and as, the situation escalates, there should be a single point of contact with the
authorities. This would be the Operator of the well (ie BP) and a note should be sent to
SEPA naming the point of contact.

March 2002 Issue 1/AM01 Add 2-1
The Operator is required to make all ‘reasonable’ efforts to recover the source. If this is
not possible, then effort should be made, as far as reasonably practicable, to reduce the
possible environmental effects of leaving the source. As operations to recover the
source progress, SEPA should be kept informed on a frequent basis.
Before abandoning the source, the Operator must obtain the consent (or no objection
note) from SEPA for their proposed plan. Paragraph 3.1 outlines the level of information
and review required.
The formal submission should be made in person to SEPA; this will enable any further
questions to be answered rapidly. SEPA will probably take some time to consider the
submission before issuing their decision. Normally this will be within one day, depending
on which agencies they need to consult. Again, this consent must be received, normally
verbally or by fax, before any abandonment operations commence.
On completion of the proposed actions (ie abandonment and sidetrack) a formal note
Uncontrolled
should be sent to SEPA so that the action file can be closed.
There is no requirement to inform the Health and Safety Executive of the occurrence.
A source being lost in a well does not come within the Reporting of Injuries, Diseases
and Dangerous Occurrences Regulations (RIDDOR); this legislation would only apply if
there were an escape of radioactive materials. However, it is strongly recommended
that the relevant Well Inspector in the Offshore Safety Division is kept informed of
developments. If SEPA requires advice on drilling matters it would normally contact the
Health and Safety Executive.
Similarly, informal notification should be made to the Health and Safety Executive
Radiation Division in Edinburgh.
If a source is irretrievable, an internal BP Tr@ction report and Serious Occurrence Report
must be raised and distributed as per normal procedures. This must be done as the
event was a reportable incident and normally represents a business loss.
The owner of the source will need to inform their licensor of the incident.
3.1 Formal Submission Guidelines

To gain the consent of SEPA, BP will need to make a formal submission. The submission
should address or include the following items:
(1) Background to the incident.
This should include a description of the circumstances that led to the source
becoming stuck.
(2) Details of the sources. This should include, as an appendix:
(a) Details of the sources, their composition and strength.
(b) Sealed source certificate showing the ANSI/BSI/ISO classification.
(c) Latest certificate of leak test.
(3) A review of all operations carried out to attempt to recover the source. This is best
presented as a summary with the diary as an attachment.

Add 2-2 March 2002 Issue 1/AM01
(4) A justification for stopping recovery operations.

(a) The justification must be objective in its assessment.
(b) It should state that all reasonable steps have been made.
(c) It is beneficial to have an external peer review of this justification.
(5) A proposed abandonment programme (if applicable).
(a) The programme should conform to BP policy and recommended industry
practice, ie United Kingdom Offshore Operators Association (UKOOA)
Guidelines for the Suspension and Abandonment of Wells.
(b) If applicable the programme will be reviewed in line with BP’s obligations
under the Design and Construction Regulations (DCR) (Independent Well
Examiner).
Uncontrolled
(c) The abandonment plugs should be verified ie pressure and/or weight.

(d) If a sidetrack is proposed, then include a specific statement of how collision
with the old hole will be avoided.
(e) If proposing to sidetrack, include a plot of the proposed sidetrack indicating
the minimum separation of the new wellbore from the source.
(f) It is most likely that SEPA/EA will require to sign the wellhead or xmas tree
to indicate that there is a nuclear source in the well, even if the source is
being abandoned. The wellhead plaque will need the depth of source,
isotope type and strength.
(6) A review of the residual hazard from the abandoned sources.
(a) A group incorporating the necessary expertise should carry out the review.
Suggested representatives would be:
(i) BP Drilling Representative – Senior Drilling Engineer.
(ii) Performance Unit (PU) Environmental Adviser.
(iii) PU Health, Safety and Environment (HSE) Adviser.
(iv) BP Radiological Protection Adviser (RPA).
(v) Logging company representative.
(vi) Logging company RPA.
(b) The review should address the following issues:
(i) Likelihood of sources coming to surface.
(ii) Short and long-term integrity of the source.
(iii) Consequences of leakage.
(iv) Production of contaminated fluids.
(v) Possibility of drilling into or damaging the source.
(vi) Recording of the presence of the source for the future.

(c) The review and consequent mitigating actions should be minuted.

(d) There should be a clear statement of the hazard/risk level once mitigations
are in place.
4 Contact List
Contacts Contact Name Address Telephone

Scottish David Orr Greyhope House Tel: 01224 248338
Environmental Neil Smith Greyhope Road Fax: 01224 248591
Protection Agency Torry
(SEPA) Aberdeen
AB11 9RD
Uncontrolled
Environment Rivers House Tel: 01258 456080
Agency Sunrise Business Park Fax: 01258 455998
Higher Shaftsbury Road
Blandford
Dorset
DT11 8ST
Health and Safety Lindsey Cairns Belford House Tel: 0131 247 2000
Executive 59 Belford Road Fax: 0131 247 2121
(Radiation Division) Edinburgh
EH4 3UE
Health and Safety Donald Dobson Lord Cullen House Tel: 01224 252500
Executive (Offshore Fraser Place Fax: 01224 252615
Safety Division) Aberdeen
AB9 1UB
Synetix Graham Wales Unit 4 Tel: 01224 826628
The Technology Centre Fax: 01224 827095
Claymore Drive
Bridge of Don
Aberdeen

5 Example A Generic Risk Assessment Format
Operation Risk Assessment

Impact of nuclear logging sources remaining in well XYZ well sump during normal
flowing operations. Sources are Cs137 and Minitron H3.
Conclusion
The Risk Assessment Team considers that after application of control measures there is
a low identified residual risk to personnel and equipment. Thus, there is no identified
impediment to flowing the well without running a bridge plug. However to eliminate the
potential for radioactive particulate returns to surface, reasonable measures should be
taken to run a permanent bridge plug above the fish and below the bottom perforations
Uncontrolled
at the earliest practicable opportunity.
Issue Assessment Team Meeting Prepared Approved Document

Date By By Number
2 Team Leader: X 10/5/2000 NAC N/A
(refer Note)
Team Leader: Y (BP)
Team Leader: Z (BP)
Team Leader: W (B/A,
Schlumberger, Reeves)
Note: Post meeting update 19 and 24 May 2000, risk assessment revisited to include
impact of Minitron H3 source and closeout action status.
Risk Assessment Inputs and Reference Documents

• Issue 1 risk assessment dated 10/5/2000: Well XYZ – return to normal flowing
operations with toolstring containing Cs137 source in sump
• Well XYZ intervention programme
• Email, W, Schlumberger 11/5/2000

Action Log
Assigned Person Action Item Details Action Response Closed out/Date

W Confirm source material Source material 11/5/2000 – Cs137
spec information provided
12/5/2000 – H3
11/5/2000
W Confirm source Encapsulation 11/5/2000
encapsulation material material data
spec and pressure provided
rating
X Define sampling and Sampling arranged First result
monitoring 12/2000 with Synetix returned
requirements 16/5/2000. No
Uncontrolled
Am241, Cs137 or
H3 detected
X Prepare plate to mark Installation advised Traffolite plate on
hazard on wellhead 10/5/2000 wellhead
14/5/2000
Y • Engineer programme Proposal discussed.
to run full bore drift Planned for
and bridge plug Intervention
campaign, 5 to 19
• Monitor tools for
June 2000
contamination on
return to surface
Z Review material
resilience in well
environment
X Update well file Initial update 10/5 Ongoing
documentation and 16/5/2000 by
well systems

Uncontrolled
Risk/Hazard Consequence C P R Control Measures Operation Safety
Residual Residual
Risk Risk
Sources remain in toolstring and irradiate wellbore Contamination of plant and L L L Normal operation. No additional control measures required L L
fluids causing irradiated sump fluid returns to surface injury to personnel
(normal operation)
Source released from tool retainer into sump due to Contamination of plant and M M M • Update well file documentation* (L)* (L)*
degradation and radioactivity reaches surface injury to personnel • Sample produced fluid weekly
• Plate attached to well xmas tree stating source data, location
Hazard Assessment
in well and nature of hazard

• Source 30ft below tool top
• Tool design (hinged Cs137 source door, two screws retain door,
double encapsulated source)
• H3 source is ceramic encapsulated within sealed tool body
• Material spec*
• Pressure rating*
• Static environment – sump has no flow

• Sump contains high viscosity residues from drilling operation –
oil-based mud, wax, asphaltenes
Source degradation over time following release from Contamination of plant and M M M • Update well file documentation* (L)* (L)*
tool retainer and failure of encapsulation material due injury to personnel • Sample produced fluid weekly*
to corrosive nature of wellbore fluids • Plate attached to well xmas tree stating source data, location
in well and nature of hazard*
• Tool design (hinged source door, two screws retain door,
double encapsulated source)
• H3 source is ceramic encapsulated within sealed tool body
• Material spec*
• Pressure rating*
• Static environment – sump has no flow and so no potential for
dynamic erosion
Future well intervention activity – toolstring damaged Contamination of plant and M M M • Review need for future interventions/review options (L) (L)
by dropped tool leading to acceleration of source injury to personnel • Hold-up depth higher than fish
release • Well deviation would slow descent
• Service company procedures
• Job planning – programme
• Pre-job safety meeting
• Potentially isolate sump from tool*
• Monitor tools for contamination on return to surface*
Source returned to surface Contamination of plant and M L M • Density of sources are greater than sump fluid – will fall due L L
injury to personnel to gravity
• 220ft below nearest flowpath – static sump
• Sump contains high viscosity residues from drilling
operation – oil-based mud, wax, asphaltenes
Isolate source by running full bore wireline plug to Plug sticks above perfs, M M M • Run plug diameter drift before running plug L L
position below perfs and above fish necessitating further fishing • Job planning – programme
ops to retrieve • Service company procedures
* Refer to Action Log to assign action. C = Consequence P = Probability R = Risk UKCSSOP004_027.ai
Add 2-7
UKCS-SOP-004
6 Example B Generic Risk Assessment Format
Operation Risk Assessment

Impact of leaving irretrievable radioactive logging sources in (Installation well).
The sources are Am241Be and Cs137.
Conclusion
The Risk Assessment Team considers that after abandonment and application of control
measures there is a low identified residual risk to personnel, the environment
and equipment. Thus, there is no identified impediment to abandoning the sources.
Uncontrolled
Assessment Team Position Company
Snr Drilling Engineer
Snr Environmental Adviser
Snr Environmental Adviser
HSE Adviser
Customer Service Manager
Radiation Protection Adviser
E-line Specialist
Date of review meeting: 7 November 2001.
Action Log
Assigned Person Action Item Details Action Response Closed out/Date

Ensure details are Details will be at the Due end November
recorded in well file. end of the well
Update well file report and well
documentation history
Ensure signage • Outline design Due end November
prepared for attached at end of well
wellhead • Installation to be
advised
Ensure sidetrack To be done in Due week

planning includes sidetrack planning commencing 12th
adequate major risk and programme November
planning approval

Uncontrolled
Risk/Hazard Consequence C P R Control Measures Operation Safety
Residual Residual
Risk Risk
Source pressure vessel integrity (short-term risks) Leak radioactive material and H L M • Pellet double encapsulated source conforms to ISO 2919 L L
potential to contaminate to C56535 or higher
surface • Sources in titanium housing
• Kill weight drilling fluid around the sources
• Drilling fluid oil-based mud, reducing corrosion
• Verified cement barrier between the sources and surface
• Additional liner barrier from sidetrack well
Hazard Assessment

Source pressure vessel integrity (long-term risks) Leak radioactive material and H L M • Pellet double encapsulated source conforms to ISO 2919 L L
potential to contaminate to C56535 or higher
surface • Sources in titanium housing
• Kill weight drilling fluid around the sources
• Drilling fluid is oil-based mud, reducing corrosion
• Verified cement barrier between the sources and surface
• Additional liner barrier from sidetrack well

• Full well abandonment at Installation commissioning
Future production of contaminated fluids from Contamination of plant and L L L • Pellet double encapsulated source conforms to ISO 2919 L L
another well injury to personnel C56535 or higher
• Sources in titanium housing
• Kill weight fluid around the sources
• Non-dispersible solid material
Communication with other areas of reservoir Contamination of plant and L L L • Pellet double encapsulated source conforms to ISO 2919 L L
injury to personnel C56535 or higher
• Sources in titanium housing
• Kill weight fluid around the sources
• Non-dispersible solid material
Risk of continued fishing • Damage to sources, leak M L M Decision to stop fishing at a reasonable point L L
radioactive material and
potential to contaminate
to surface
• More complicated plugging
Possibility of drilling into the wellbore in the future • Damage to sources, leak H L M • Application of BP well collision policy at 3 sigma uncertainty L L
(including sidetracking) radioactive material and • Well files recording presence of source
potential to contaminate • Well path recorded in directional database
to surface • Plaque at wellhead
• Contamination of plant and
injury to personnel
C = Consequence P = Probability R = Risk UKCSSOP004_028.ai
Add 2-9/10
UKCS-SOP-004

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Working with Radioactive Materials UKCS-SOP-004

Authorisation for Issue

Part 1 Sealed Sources, Radiation Generators and

March 2002 Issue 1/AM01 i/ii

Authorisation for Issue

Position: Operations Delivery Team Leader, GFU

Position: HSE Team Leader, UK and Faroes Exploration, UKX&F

November 2001 Issue 1 iii/iv

For Audit Use

November 2001 Issue 1 v/vi

Issue No Date Description

March 2002 Issue 1/AM01 vii/viii

Holders of Controlled Hard Copy

Copy Copyholder Location

01 Data Control Centre (DCC) ODL, Aberdeen

01 Document Issue Authority (John Watson)

March 2002 Issue 1/AM01 ix/x

control of the problems resulting from the presence of such material.

November 2001 Issue 1 xi

The Use/Occurrence of Radioactive Materials in the

xii November 2001 Issue 1

Unsealed Radioactive Material

Installation Manager/Site Manager

November 2001 Issue 1 xiii

Federal Health, Safety and Environment (HSE) Delivery Team

Radiation Protection Adviser

xiv November 2001 Issue 1

Radiation Protection Supervisor

Nominated Person – Company Appointment

Review and Update

November 2001 Issue 1 xv

xvi November 2001 Issue 1

ALARA As Low As Reasonably Achievable

ETA Estimated Time of Arrival

March 2002 Issue 1/AM01 xvii

List of Abbreviations (cont’d)

xviii March 2002 Issue 1/AM01

Section 1 Sealed Sources

Section 2 Unsealed Radioactive Material (Radiotracers)

Section 4 Local Rules

2 Description of Sealed Sources 1-1

3 Statutory Testing 1-1

4 Registrations and Authorisations 1-2

6 Storage of Radioactive Materials 1-3

7 Accounting for Sealed Sources 1-3

8 Routine Physical Checks 1-4

9 Radiation Monitors 1-5

10 Radiation Monitoring 1-5

11 Controlled and Supervised Radiation Areas 1-5

12 Prevention of Accidental Exposure 1-7

13 Contingency Plan 1-8

14 Contractors Using Radioactive

Part 1 Sealed Sources

2 Description of Sealed Sources

Part 1 Sealed Sources

4 Registrations and Authorisations

Sealed Sources Part 1

6 Storage of Radioactive Materials

7 Accounting for Sealed Sources