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Radiation Protection Requirements for Industrial Radiography (RPS C-4)

ARPANSA is inviting submissions on the draft code Radiation Protection Requirements for Industrial Radiography (Industrial Radiography Code).

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The Issue
Start/End Date: 
Tuesday 9 January 2018 - 09:00 to Monday 26 February 2018 - 17:00

The Industrial Radiography Code sets the specific radiation protection requirements in Australia for the protection of occupationally exposed persons and the public in planned exposure situations involving industrial radiography. It complements the overarching requirements contained in Radiation Protection in Planned Exposure Situations (Radiation Protection Series C-1).

The Industrial Radiography Code applies to all aspects of industrial radiography from the sale and supply of industrial radiography radiation equipment and sealed radioactive sources to the applied use and safe storage of such equipment and sources. If followed, the requirements of the Industrial Radiography Code should ensure that unnecessary exposure of persons to ionising radiation is avoided; all exposures are kept as low as reasonably achievable; and the dose limits specified in Radiation Protection Series C-1 are complied with.

Industrial radiography uses the penetrative properties of ionising radiation to obtain information on the internal state of inanimate objects and materials through radiographic imaging. Its application is well established and, when used in a safe and controlled manner, brings significant benefits to society.

Due to the intense radiation fields used in industrial radiography, improper use could create significant radiological health hazards including potentially lethal radiation doses. Harmful radiation doses have been received in the past by both industrial radiographers and members of the public from a variety of accidents, most of which could have been avoided had appropriate safe working practices been followed.

Personal monitoring records consistently show that doses received by industrial radiographers are amongst the highest of any group of radiation worker. Industrial radiography is carried out in a variety of environments including remote locations and under circumstances that involve serious risk of accidental exposure unless site working rules are rigorously followed.

Currently, the national standard applied to industrial radiography practices, the Code of Practice for the Safe Use of Industrial Radiography Equipment (1989) (Radiation Health Series No.31), refers to superseded equipment standards and outdated radiation dose limits. It is hybrid publication containing a mix of mandatory requirements and non-mandatory guidance. The proposed Industrial Radiography Code refers to current international equipment standards and the dose limits set in RPS C-1. It clearly sets out the mandatory radiation protection requirements to be adopted as conditions of authorisation by Australian radiation regulators.

The International Atomic Energy Agency (IAEA) publication Radiation Safety in Industrial Radiography, Specific Safety Guide No. SSG-11 (IAEA 2011) provides non-mandatory guidance to be followed by the industrial radiography sector to achieve best practice.

ARPANSA, jointly with the Radiation Health Committee, developed the Industrial Radiography Code based on the mandatory requirements in Radiation Health Series No.31 and the guidance in IAEA Specific Safety Guide No. SSG-11.

Draft - Radiation Protection Requirements for Industrial Radiography (RPS C-4)


FileDraft - Radiation Protection Requirements for Industrial Radiography (RPS C-4)

Participate

Start
9 Jan 2018 - 09:00
End
26 Feb 2018 - 17:00
Days Remaining 8 of 48

ARPANSA invites people and organisations interested in radiation protection requirements for industrial radiography to tell us their views on this topic.

Step 1: Your submission
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Files must be less than 5 MB.
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The following formal submissions have been made public.

Airflite Pty Ltd

I'd be interested to hear the justification for reducing the boundary exposure limits to 20 μSv·h-1? I hope there is some significant data to warrant such a change, rather than simply reducing the limits for the sake of it??


Duncan Esterbrook

Conducting radiography of equipment in situ requires co-ordination and negotiation with other maintenance activities being conducted on adjacent fixed plant which can not be moved. Increasing the exclusion zone from 25µSv to 20µSv may cause significant disruption. When adjacent maintenance personnel may only receive <10 minutes exposure per year. The measurable benefit is questionable when this change could result in radiography being removed from the scope of works.


Inspections X-Ray & Testing

It displays a lack of understanding to believe that a 20% reduction of allowable dose rate at the boundary will lead to any significant reduction in dose. In some cases it will mean a longer exposure at a lower energy setting and no change in dose? Practical examples of ALARP in the document, such as larger collimators and lead sheet shielding, from people who actually work in the industry would have a much better chance of lower doses compared to a simplistic maximum dose rate reduction.


Kyle Brealey

The proposed reduction of the boundary exposure limit to 20µSv·h-1 would seem to me to cause much disruption to well established working practices for no benefit to the health of either the public or the operators. I would like to understand why ARPANSA believes that this is a relevant change and how they would propose to measure the change to the health of the public or the operators upon implementation.


Matthew Callanan

Please refer to the attached document for responses in regard to the draft


Nathan Lenane

This small reduction in allowable dose rate at the boundary serves no practical purpose. A reduction of 5 uSv h-1 will not have any measurable effect on radiation worker safety or non radiation worker safety. Radiographers already work using the ALARA principle using 25 uSv h-1 as the maximum allowable dose at the boundary which is very low already. Survey meters are not that accurate. This would be a change for the sake of making a change.


Neil Young

Thank you for the opportunity to comment.
I feel the reduction from 25 to 20µSv·h-1 (line 330,450,570,610,634,650) is not necessary and has no measurable outcome change. This only hurts industry by having to extend barriers further OR worse that industry may not practically adopt the change due to the difficulty i.e i doubt companies will redesign their partially enclosed exposure bays for 5 µSv·h-1. This is a great expense for minimal outcome? Has there been any research or evidence on this