Radiation Exposure Control Plan

The use of Nova Radiographic Exposure Devices is limited to Nova Advanced Imaging Inc. employees under the supervision of the corporations Radiation Safety Officer (RSO). Nova and its employees are trained to carry out Industrial Radiography operations according to the WorkSafeBC Act - Section 7 and the National Safety Code #34. Furthermore, Nova has adopted the American Society for Non-Destructive Testing (ASNT) principles, which provide guidelines for employers to establish certification programs for the qualification and certification of non-destructive testing personnel.

Purpose:

The purpose of the Radiation Exposure Control Plan is to ensure that the x-ray inspection process is applied consistently, so that expected results can be achieved with confidence.

Nova Advanced Imaging Inc. Responsibilities

Nova Advanced Imaging Inc. will ensure:

  • That the tools, equipment, personal protective equipment and other resources required to fully implement and maintain this E.C.P are readily available.
  • Ensure that supervisors and workers are educated in the hazards of radiation.
  • Maintain written records of training
  • Conduct an annual review (or more often if conditions change) of the effectiveness of the E.C.P. This includes a WorkSafeBC and or Section 34 review.
  • Coordinate work with prime contractors and other employers to ensure a safe work environment.

Radiation Safety Officer Duties and Responsibilities

Nova’s Radiation Safety Officer is assigned the overall responsibility for coordinating and implementing radiation safety and training for all operating employees. The Radiation Safety Officer must ensure that all operating employees are knowledgeable in the company’s operating procedures and the rules of the company’s regulations. The RSO and/or the Assistant Radiation Safety Officer (ARSO) is responsible for the daily radiography operations.

The specific duties and responsibilities of the RSO and the ARSO consist of, but are not limited to, the following:

  1. Assuring that all activities (storage, transportation, use, maintenance and abandonment) involving industrial radiographic equipment (devices) are conducted in accordance with all applicable federal or provincial regulations, applicable procedures, company policies, notices, directives, memorandums and instructions.
  2. The RSO is required to read and understand the regulations and procedures, and to be familiar with all applicable regulatory requirements.
  3. The RSO is to assure that Only authorized users have access to industrial radiographic equipment at all times while in storage, during transportation, and while in use.
  4. The RSO is to maintain copies of all applicable required records on file, in an organized manner, available for inspection.
  5. The RSO is to assure that all industrial radiographic equipment is transported in accordance with all applicable federal/provincial transportation regulations, local requirements, and applicable procedures. Also, to assure that all required transportation labels and markings are complete and legible, and that the documentations required for each device is up-to-date and complete.
  6. The RSO is to provide assistance and information to the president on all matters relating to radiation safety and the radiation safety program.
  7. The RSO is to identify and report regulatory violations and/or items of noncompliance and take actions to remedy the situations and set up a preventative action plan.
  8. The RSO has the authorization to perform actions necessary to ensure the safety of Company employees and the safety of the members of the public.

Education & Training

Nova Advanced Imaging Inc. has accepted the American Society for Non-Destructive Testing Certification (ASNT) requirements, which detail how Nova personnel are trained, qualified and certified to perform digital x-raying.

The Exposure Device Operator certification has been developed for the following purposes:

  • To verify the knowledge, skills and abilities of personnel operating exposure devices used in industrial radiography
  • To protect the health, safety and security of the public, workers and the environment
  • To meet the requirements of the WorkSafeBC Act, Section 7 and the National Safety Code #34 (Regulations Governing Industrial Radiography)
  • To encourage consistency and best practice throughout the radiography industry and to promote strong radiation safety culture and security requirements.

Risk Identification and Assessment

When performing radiographic operations Nova Advanced Imaging Inc. technicians follow the procedures outlined in the Nova Advanced Imaging General Procedures Manual for assuring safe work practices while performing industrial radiography at client facilities. The procedures and techniques in performing day to day operations are very important if radiation exposure is to be minimized. It is important to follow the instructions set out in this E.C.P as they will minimize the possibility of exposure to you, clients and the general public.

Nova Advanced Imaging Inc. uses the latest portable Direct Radiography (DR) imaging system. Direct Radiography exposes a digital panel unlike conventional x-raying, which uses film.

Nova uses one of two portable x-ray generators. The “pulsed x-ray source” is a lightweight x-ray generator that operates on its own removable battery pack. The source is of the pulsed x-ray type that produces x-ray pulses of very short duration (50 nanoseconds). Typically, concrete x-rays take 9 to 18 seconds to complete. The Evo 300d source is a large x-ray generator that operates on 110v power. The source has a large variance in kV and mA, which requires larger exclusion zones and x-rays can last up to 3 minutes in length.

When performing Digital X-Raying it is necessary to carefully evaluate the area that requires x-raying. The intended area in front of the unit, behind, above, and below the intended area needs careful examination to determine what level of shielding the surrounding structures will provide and to establish if digital x-raying can be performed. Nova technicians will determine this on the initial site visit to ascertain the overall safety considerations of performing industrial radiography at that location.

Work locations where workers or other persons are exposed to the hazards of radiation will be identified with signs, placards, or barrier tape.

The factors of time, distance and shielding are to be considered in each radiography exposure made.

During the duration of an exposure, you should stay as far from the source of radiation as possible. The intensity of the radiation field decreases by an amount inversely proportionate to the square of the distance from the source. The INVERSE SQUARE LAW is the formula for this purpose. You may use the quick and easy rule of thumb, IF THE DISTANCE IS DOUBLED THE RADIATION LEVEL IS REDUCED BY A QUARTER. Therefore, the intensity is very high close to the source.

When making an exposure, take advantage of "natural shielding" such as a concrete wall, pipe racks, vessels, etc.

In summary, stay as far as practical from the source when the x-ray source is shooting. With the intelligent use of your survey meter, this will result in significantly reducing your personal radiation exposure.

Radiation Control Best Practices:

Prior to the initial establishment of a controlled area at a job site for purposes of performing radiography, the responsible Radiography technician in charge of the operation shall notify appropriate supervisory or management personnel of the customer and other companies working the vicinity that x-raying will be performed. This notification should include a statement of your responsibility for maintaining "CONTROLLED RADIATION AREAS" and a request for their cooperation. Advise such Management personnel that violation of the restricted area by other workers on the job will result in the operation being halted.

Calculate and establish the required distances and post "CONTROLLED RADIATION" areas.

Maintain visual surveillance of controlled areas then proceed with exposure.

Nova Advanced Imaging Inc. has a duty to protect its workers and the general public from radiation exposure during digital x-raying. Effective controls and procedures are available to protect workers from such harmful exposure.

ALARA is an acronym for “As Low As Reasonably Achievable”. This is a radiation safety principle for minimizing radiation doses by employing all reasonable methods. ALARA is not only a sound safety principle, but is a regulatory requirement for all radiation safety programs.

Three cardinal principles of ALARA are ‘Time’, ‘Distance’ and ‘Shielding’. A combination of these 3 methods will be required to achieve the ALARA principle. Nova is committed to being diligent in its efforts to select the most effective control technologies available, and to ensure that the best practices, as described in this exposure control plan (E.C.P), are followed at its worksites.

Radiation Exposure Limits

A worker's exposure to ionizing radiation must not exceed any of the following:

(a) an annual effective dose of 20 mSv
(b) an annual equivalent dose of

(i) 150 mSv to the lens of the eye,
(ii) 500 mSv to the skin,
(iii) 500 mSv to the hands and feet.

.02 mSv per hour maximum exposure limit

1 mSv per 7 days’ maximum exposure limit

Annual Review

  • This ECP will be reviewed at least annually and updated as necessary by the employer, in consultation with the workplace health and safety committee or the worker health and safety representative.

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