Military reference books and manuals (2009-2023, Volume 4)

AZSPU-HSSE-DOC-00054-2

Page 52 of 61

Incident Investigation and Reporting

APPENDIX I - ONSHORE OPERATIONS EXTERNAL NOTIFICATION

REQUIREMENTS

What

When

By Whom

To Whom

Major Incidents (MIAs)

<24hrs (verbal)

AzSPU CHSSE (Az) or

In-country Regulators

C&EA (Geo) (during

<3 days (written)

office hours) or Duty

Incident Commander

(out of office hours)

<2 days

PUL

Partners (BTC or SCP)

<3 days

BTC Commercial

BTC Lenders (BTC

MIAs only)

High Potential Incidents

<24 hrs (verbal)

AzSPU CHSSE (Az) or

In-country Regulators

(HiPos)

C&EA (Geo) (during

<3 days (written)

office hours) or Duty

Incident Commander

(out of office hours)

<2 days

PUL

BTC or SCP Partners

<3 days

BTC Commercial

BTC Lenders (BTC

HiPos only)

Any other Incident (that

<5 days

Onshore PU E&S

BTC Lenders

is not an MIA or HiPo)

Manager

(Environmental

Incidents only)

Spill / material release

24 hrs verbal

CHSSE External

Regulatory notification

to the environment (i.e.

Relations (Az) or C&EA

72 hrs written

that breach secondary

Teams (Geo)

containment) that is not

an MIA or HiPo

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

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AZSPU-HSSE-DOC-00054-2

Page 53 of 61

Incident Investigation and Reporting

APPENDIX J - INCIDENT CLASSIFICATION, RESOLUTION PROCEDURE

Incident Classification - Resolution Procedure

 The business line shall be accountable for reporting HSSE data in accordance with the requirements of this

practice. Group S&O provides specific subject matter expertise on HSSE topics to support accurate and

consistent reporting. S&O finance is accountable for providing assurance on the integrity of all group HSSE

data.

 Clarification on the reportability or classification of specific HSSE incidents may be requested by group

S&O or by S&O finance. These may include, for example, whether an incident is work-related, whether an

injury is properly classified as DAFWC or a recordable Injury, whether or how an incident is properly

classified as Loss of Primary Containment (LOPC), or incident severity classification.

 Request for clarification from group S&O or S&O finance shall be directed to the line initially through the

relevant segment HSSE functional lead or function HSSE equivalent. In response, line management shall

consult with local and BP group subject matter experts as needed.

 If a difference of view is identified and not resolved by this means, the issue shall be referred to S&O HSSE

head of discipline and S&O finance manager who shall consult with representatives from the segment (or

equivalent) and, if appropriate, with resources outside the company before advising line management of their

recommendation.

 In order to reach resolution, it may be necessary to escalate through both the line and the functional

organizations. Ultimate authority for classification resolution resides with executive management.

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

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AZSPU-HSSE-DOC-00054-2

Page 54 of 61

Incident Investigation and Reporting

APPENDIX K - INITIAL INTERNAL INCIDENT NOTIFICATION FORM

To assist with verbal notification of MIAs, HiPOs, all injury/illness incidents and all

production loss events.

Notification of :

(insert incident title)

(VP Group / Operating Area / Facility / Specific Location etc)

Location:

Date of the

Event:

Time of the

Event:

Brief

Description:

Injury/Illness

Details:

Damage/Loss

Details:

Likely Causes:

Immediate

Actions Taken:

Potential:

Person reported

the Incident

Person Leading

the

Investigation, if

known:

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

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AZSPU-HSSE-DOC-00054-2

Page 55 of 61

Incident Investigation and Reporting

APPENDIX L - GUIDANCE ON USE OF DROPS CALCULATOR AND DROPPED

OBJECT HIPO DETERMINATION.

The DROPS calculator is effectively a graph template upon which a dropped object „is

plotted‟, based upon the mass of the object and the distance that it fell, in order to determine

its potential effects.

The graph is based on three probit functions. A probit function indicates the relationship

between exposure and the probability that the consequential risk takes place. This is a

method which is currently available to determine the effects of dropped objects:

 With light objects (<0.1kg) the most important effect is the skin being punched and the

tissue/organic functions being damaged; this criteria can be used for incidents such as

breaking glass flying around or metal particles

 With heavier objects (>0.1kg) the effects of skull fractures are used

All dropped objects that occur on, or at, a BP establishment or location, or as a result of BP-

related work, shall be appropriately assessed and reported.

Whilst the actual severity of any dropped object is generally easy to determine, it is important

that in all cases the most likely potential severity of the dropped object is understood.

To assist in understanding the most likely potential severity, the AzSPU uses the industry

standard Dropped Objects Prevention Scheme

(DROPS) consequence calculator, the

DROPS calculator.

Use the DROPS calculator to establish the likely severity.

Note: The use of DROPS gives an indication of the likely severity of a dropped object and in

any analysis, the following questions should be considered:

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

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Page 56 of 61

Incident Investigation and Reporting

 Was the energy potential expended in some way as the object fell (ie deflected by

pipework)? If so, you should assume that DROPS may have overestimated the likely

potential severity.

 Was the object that „dropped‟ of differing size? The DROPS calculator was based on an

object delivering a force over a small surface area (point load), so the force delivered

from an object of differing size and makeup needs to be considered.

 Was the dropped object made of solid material? DROPS assumes a solid object. In

some rare cases the material may not always be solid and DROPS may have therefore

overestimated the likely potential severity.

 Did the object fall into a „barriered off‟ area or an area where no personnel were present?

If so then this would again have the effect of lowering the likely potential severity

indicated by DROPS.

Note: Any reassessment of the likely severity as a result of any of the above questions is

going to be subjective, the purpose of this guidance is to ensure that a meaningful review of

the likely potential severity indicated by the DROPS calculator is carried out, even if the

eventual outcome remains unchanged.

Decide whether the incident is BP reportable as a HiPo.

The ultimate potential of any dropped object incident is determined by asking what the most

serious probable outcome would have been. For a HiPo, the most relevant serious probable

outcome refers to those incidents that could have led to either:

 A fatality associated with BP operations

 Multiple serious injuries

 A significant adverse reaction from authorities, media, NGOs or the general public

 The cost of accidental damage exceeding US $500,000

In reaching a conclusion as to the likely potential severity of a dropped object incident,

further consideration shall also be given to the following:

The location in which the object falls. In the extreme, a heavy object falling into the sea

would not raise any question in terms of a likely personnel injury outcome (provided a vessel

was not present and no diving operations were ongoing), so the same would apply to

locations on a platform or rig which are rarely accessed by people.

There has to be proximity - for a dropped object incident to be defined as a BP recordable

HiPo, the following two criteria must be met:

 An individual needs to be close to the impact area when the dropped object actually

lands, and

 In a position where it would be reasonable to assume that in slightly different

circumstances they could have been struck by the object (ie they have just left the area

where it actually landed)

There has to be some kind of reported incident. So as a guide, if an object (that had clearly

dropped) was „found‟ on the floor and was of a weight that would have potentially resulted in

a fatality, but the incident had not been observed or heard, then the assumption would be

that nobody was present and it would not be reportable as a HiPo.

The fact that an area has been barriered off to keep people away from a potential dropped

object situation is valid grounds to declare that there was no risk of injury.

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

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AZSPU-HSSE-DOC-00054-2

Page 58 of 61

Incident Investigation and Reporting

REVISION/REVIEW LOG

Revision Date

Authority

Custodian

Revision Details

23 February 2006

Alan McNuilty

Abbas Islamov

Initial Issue

09 July 2007

Alan McNuilty

Abbas Islamov

The major changes made in the document

cover the following areas:

 Clarity on individual Roles and

responsibilities and incident owners based

on severity of incident

 Process for notification of MIA/HiPo

incidents to Group and AzSPU Senior

Management

 Clarity on the procedure for classification

and initiation of DAFWC/HiPo/MIA

investigations

 Actions setting and prioritization - note

change from targets based on prescriptive

dates to agreed timescales between

actionee and action owner

 Approval process - owner and approver is

now the same person

 Removal of "Spheres of Influence"

 Roles and responsibilities

 MIA/HiPo notification

 Investigation Process

 Actions setting and prioritization

30 April 2008

Alan McNuilty

Rufat Mamedov

The major changes made in the document

cover the following areas:

 Tr@ction and MIA/HiPo Database

recording requirements

 Incident Notification Requirements clarified

in Figure 3.1

 Included Figure 4.1 “Guidelines to Assess

Potential Severity”

 Update to figure 4.2 “HiPo determination

flowchart” in light of new Group severity

matrices

 Included section on ABC Analysis

 Requirements for AzSPU outside

distribution requirements for HiPlus,

Lessons Learned one pager and similar

documents.

 New Comprehensive List of Causes (CLC)

Chart

 Appendix E renamed to “Definitions” and

definitions were updated in light of new BP

Group F&CA HSE Definitions and OMS

GDPs 44-00-01 and GDPs 44-00-02

 new severity matrices

 Export PU Internal Notification

requirements for illegal taps

 Onshore Operations External Notification

Requirements

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

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Page 59 of 61

Incident Investigation and Reporting

Revision Date

Authority

Custodian

Revision Details

30 April 2009

Yuliy Zaytsev

Rufat Mamedov

The major changes made in the document cover

the following areas:



Added definition of Marine related Incident



Added Marine Authority responsibilities



Added the requirement to consult BP legal

for Level A-E incidents



Added the requirement to provide a relief

from normal duties for Investigation Team

Members



Added “Training Requirements and

Competence” section



Added additional incident notification

requirements for Marine related incidents in

“Reporting and Notification Requirements”

section



Removed LOPC from Major Incident

definition to reflect that LOPC on itself

doesn‟t constitute Major Incident unless

causing MI in “H&S, Environment, Property

damage” severity levels



Updated HiPo determination chart by

removing LOPC box reflecting the above

point



Added Appendix N, specifying level of

investigation required depending on actual

severity level



Revised HiPo definition



Revised minimum requirement for

investigation team composition for MIA and

HiPo incident



Added Appendix O, giving an example of

formal incident investigation report

25 May 2009

Yuliy Zaytsev

Rufat Mamedov

The major changes made in the document cover

the following areas:

 Timeline for completing formal incident

investigation report - Section 5.11

 AzSPU specific protocol and process

timeline established for development and

distribution of LL reports - Section 7

8 July 2009

Yuliy Zaytsev

Rufat Mamedov

The major changes made in the document cover

the following areas:

 Added definition and guidance for “Loss of

Primary Containment” (LOPC)

 Added “Primary Containment” definition

 Added definition on “Unsafe/Unhealthy

condition”

 Added “Incident Investigation” definition

 Added Major Incident guidance

 Added “Process Safety” and “Process Safety

incident” definitions

 Added definition of “Injure/Illness”

 Added “Occupational Injury” and

“Occupational Illness” definitions

 Revised “Recordable Occupational Illness

and Injury” definition

 Revised “Medical Treatment Case” definition

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

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Page 60 of 61

Incident Investigation and Reporting

 Added “Equipment /Property Damage”

(Incident Direct Cost)

 Added Business Travel - BP employee and

Business Travel - Contractor definition

 Added another column into the 2.1 table

describing information use internally and

externally

 Added definition of an “Explosion”

 Added definition of “Fire”

 Added definition for “Severe Vehicle

Accident”

 Added definition on “Uncontrolled

Release/Event”

20 October

Yuliy Zaytsev

Rufat Mamedov

 Added definition of “IM related incident”

2009

19 January

Yuliy Zaytsev

Rufat Mamedov

Main reason for the revision was the issue of

2010

updated GDP 4.4-0001 and GDP 4.4-0002.

Details are:



Incident notification flowchart has been

revised to reflect that all MIA e-mail

notifications to the Group relaxed from 8 to

24 hours.



Requirement to advise BP legal on any MIA

incident and other incidents with possibility of

regulatory action or litigation.



Requirement not to enter incident into

traction if information contained is classified

as “BP confidential”.



“Incident Classification” section has been

added.



Training requirements for Fatality incident

investigation team leader.



AzSPU incident distribution lists have been

revised.



Requirement to notify regional security

advisor for MIA and HIPO security incidents

which may not be in public domain.



Requirement to notify BP regional health

director for fatalities resulting from natural

causes or self-inflicted.



Details on required level of investigation and

investigation team make-up.



“Guidelines to assess potential severity”

(Figure 6.1) has been updated.



“HiPo determination flowchart” has been

updated.



“Storage of records” section has been

updated.



Severity Matrices and Potential LOPC

severity matrices have been updated.

“Business Value Loss” severity category has

been removed.



“Definition” section has been revised.



Formats for LL one Pager, CLC chart,

MIA/HiPO announcement and RCA

investigation report have been removed as

appendices. Uploaded to Dk and links

provided within the document.

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

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Page 61 of 61

Incident Investigation and Reporting

08 February

Yuliy Zaytsev

Rufat Mamedov



Updated incident notification flowchart to

2010

reflect notification requirements for BIL

MIA/HiPo incidents.



Added section on HSSE & Operational

Incident Reporting Boundaries



Added the requirement to classify incident

relatedness to PS, IM, CoW, Driving, Marine,

Security when entering incident into Traction



Requirement to inter incident relatedness to

PS, IM, CoW, Driving, Marine, Security into

One Pager LL summary.



Requirement to initially report the incident

even if in doubt as to whether incident is

within reportable boundaries.

21 June, 2010

Yuliy Zaytsev

Rufat Mamedov



Revised and updated R&R as part of Sector

Leadership Functional Organisation.



Revised “incident owner” section.



Clarified drilling related incidents notification

requirements.



Added Initial Internal Incident Notification

form as Appendix K.



Updated Reference Section.



Slight update to section “HSE & Operational

Incident Reporting Boundaries”.

17 September,

Yuliy Zaytsev

Rufat Mamedov



Added requirement to mark the formal RCA

2010

investigation report as

“Draft” or

“Final” to

ensure only action from final report are

entered into traction.

08 October,

Yuliy Zaytsev

Rufat Mamedov



Slight change to section

9 to bring more

2010

clarity on investigation reports retention

schedule.

6 December,

Yuliy Zaytsev

Rufat Mamedov



Added Appendix L for “Guidance on use of

2010

DROPS Calculator and Dropped Object

HiPo determination”.



Added Figure 10.2 to Section 10 to bring

clarity on BP Operational Boundaries for

AzSPU.



Added AzSPU Entity Aviation Authority

(EAA) roles and responsibilities and

expanded Logistic Manager responsibility to

notify EAA on aviation related incidents.



Section 1.2 was updated to ensure that all

drilling and well operations safety and

integrity management accidents, incidents

and significant near misses are investigated.



Added Process Safety Incident Classification

Guidance as Appendix M.

Control Tier:

Revision Date: 06 January, 2011

Document Number: AZSPU-HSSE-DOC-00054-2

Print Date: 1 February 2011

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AzSPU Procedure for Management of NORM

Page 1 of 20

AzSPU Procedure for

Management of Naturally Occurring

Radioactive Material (NORM)

AzSPU-HSSE-DOC-00097-2

Authority:

Yuliy Zaytsev (AzSPU

Custodian:

Idrak Nazarov (AzSPU HSE MS Team

Safety & Compliance

Leader)

Manager)

Scope:

AzSPU

Document

AzSPU HSSE MS Document Co-

Administrator:

ordinator

Issue Date:

7^th October, 2009

Issuing Dept:

AzSPU HSSE

Revision

Control Tier:

2- AzSPU

Date:

Next Review

7^th October, 2010

Date:

Control Tier: 2

Initial Issue:

7 October, 2009

Document Number: AZSPU-HSSE-DOC-00097-2

Print Date: 2/1/2011

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AzSPU Procedure for Management of NORM

Page 2 of 20

TABLE OF CONTENTS

Purpose/Scope

Definitions

General Requirements

Key Responsibilities

Procedure

5.1

NORM Overview

5.2

Monitoring for NORM

5.3

Preparation for Work Involving NORM

5.3.1

Risk Assessment

5.3.2

Training

5.3.3

NORM Handling Materials

5.3.4

Personal Protective Equipment

5.3.5

Breaking Containment

5.4

Storage Arrangements for NORM Contaminated Material

5.4.1

Handling

5.4.2

Marking and Labelling of NORM Contaminated Material

5.4.3

NORM Storage Areas

5.4.4

Records & Inspection

5.5

Transportation & Disposal of NORM Contaminated Equipment and Waste.. 13

Key Documents/Tools/References

Appendix A - NORM Monitoring of Tubulars

Appendix B - NORM Contamination Monitoring Log

Appendix C - NORM Survey Report

Appendix D - Sampling Protocol for NORM

Appendix E - NORM Sample Register

Appendix F - NORM Waste Accumulation and Storage Record

Control Tier: 2

Initial Issue:

7 October, 2009

Document Number: AZSPU-HSSE-DOC-00097-2

Print Date: 2/1/2011

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AzSPU Procedure for Management of NORM

Page 3 of 20

Purpose/Scope

This procedure provides instructions for work involving Naturally Occurring Radioactive

Material (NORM) to ensure that it is carried out safely, and in accordance with applicable

legislation and standards.

This procedure applies to all work involving NORM carried out by, or on behalf of, the

Azerbaijan Strategic Performance Unit (AzSPU).

Revision of this procedure and the operational controls detailed therein will be in accordance

with the AzSPU HSSE Document Management Procedure (AzSPU-HSSE-DOC-00025-2).

Definitions

Refer to document AzSPU HSSE Definitions AzSPU-HSSE-DOC-00021-2 for definitions

common to this HSSE&S MS.

Definitions specific to radiation management are included in Appendix A of the AzSPU

Procedure for Management of Radioactive Materials & Radiation Generators (AzSPU-HSSE-

DOC-00058-2).

General Requirements

General requirements pertaining to radiation safety are detailed in Section 3.1 of the AzSPU

Procedure for Management of Radioactive Materials and Radiation Generators (AzSPU-

HSSE-DOC-00058-2).

Radioactive Material Exemptions

Under Safety Series 115 - International Basic Safety Standards for Protection against Ionising

Radiation and for the Safety of Radiation Sources (IAEA, 1996) sources within practices are

automatically Exempted if they do not exceed specified Exemption levels of total activity or

activity concentration. For NORM containing radium-226 and radium-228, the Exemption

level for each is 10 Bq/g.

NB: Exempt material is nonetheless radioactive and should be treated as such. In addition,

there may be other properties of the waste that restrict the disposal options such as oil content.

Radioactive Waste

Radioactive waste is any scrap material, effluent, or unwanted surplus material that has been

identified as radioactive, in accordance with the definitions above.

In terms of contaminated equipment, this can only be classed as radioactive waste if it is to be

scrapped. If equipment is being cleaned (either offshore or onshore) and then re-used it is not

classed as waste. If equipment has to be cleaned before the decision is made to scrap, then it is

also not classed as waste.

Licences

In accordance with the Decree of the President of the Azerbaijan Republic on “Additional

Measures in the Area of Issuing Special Permits (Licences) for Certain Types of Activity”,

Control Tier: 2

Initial Issue:

7 October, 2009

Document Number: AZSPU-HSSE-DOC-00097-2

Print Date: 2/1/2011

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AzSPU Procedure for Management of NORM

Page 4 of 20

No. 510 (29.12.2006), a „special permission‟ is required for the storage and disposal of

radioactive and ionising waste, which is issued by the MENR.

Any AzSPU operated site that requires a „special permission‟ should discuss this with the

AzSPU Radiation Protection SPA.

Key Responsibilities

A full description of the responsibilities with regard to radiation protection is provided in

Section 4 of the AzSPU Procedure for Management of Radioactive Materials and Radiation

Generators

(AzSPU-HSSE-DOC-00058-2). A summary of key responsibilities directly

applicable to this procedure are provided below:

Site Radiation Protection Supervisor (RPS)

The site RPS is responsible for the following:

 Conducting contamination checks of equipment (using monitors).

 Establishing supervised / controlled areas, where required.

 Collecting NORM samples (where required) and arranging for them to be couriered

to the Tracerco laboratory.

 Maintaining generic risk assessments for work with NORM contaminated equipment

/ waste and providing input to task specific risk assessments.

 Carrying out on-site NORM hazard and control training, and ensuring persons

working with NORM are aware of, and understand this procedure.

 Managing the storage, handling and labelling of NORM contaminated material and

doing a weekly inventory and review of storage arrangements.

 Maintaining Site Radiation Records (NORM Contamination Monitoring Log, NORM

Survey Report, NORM Sample Register, NORM Waste Accumulation and Storage

Record, training records, etc).

 Notifying the AzSPU RP SPA if NORM waste is to be stored on site, so that a

„Special Permission‟ can be obtained.

AzSPU Radiation Protection Single Point Accountability (AzSPU RP SPA)

Responsible for:

 Maintaining a proper communication flow between the AzSPU Radiation Protection

Advisor (UK based) and the Site Radiation Protection Supervisors (RPSs).

 Liaising with MENR in order to obtain a „Special Permission‟ if NORM waste

storage is to be carried out on an AzSPU site.

AzSPU Radiation Protection Advisor (RPA)

AzSPU retains by contract and appointment a RPA to provide the AzSPU with expert advice

on radiation safety and compliance matters. The RPA reports to the AzSPU Safety &

Compliance Manager and works directly with the AzSPU RP SPA.

In terms of this procedure, the RPA will provide guidance on the following:

 Sample analysis results interpretation.

 Advice on transportation requirements and disposal route options (based on results of

sample analysis).

Control Tier: 2

Initial Issue:

7 October, 2009

Document Number: AZSPU-HSSE-DOC-00097-2

Print Date: 2/1/2011

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AzSPU Procedure for Management of NORM

Page 5 of 20

OIM / Site Manager

Accountable for ensuring that any NORM contaminated waste is transferred from site as soon

as reasonably practicable (in consultation with the site RPS).

Procedure

5.1

NORM Overview

Naturally occurring radionuclides are present at varying concentrations in the earth‟s crust and

can be concentrated and enhanced by processes associated with the recovery of oil and gas.

This „enhanced‟ NORM, often known as TENORM (Technologically Enhanced Naturally

Occurring Radioactive Material) can be created when industry activity increases the

concentrations of radioactive materials, or when the material is redistributed as a result of

human intervention or some industrial processes.

During the production process, NORM flows with the oil, gas and water mixture and

accumulates in scale, sludge and scrapings. It can also form a thin layer of film on the interior

surfaces of gas processing equipment and vessels (see Figure 1). The level of NORM

accumulation can vary substantially from one facility to another depending on the geological

formation, operational factors, and other variables. To determine whether or not a facility has

NORM contamination, NORM survey, sampling and analysis needs to be conducted.

Figure 1: The Origins of NORM, indicating where NORM may accumulate in the

recovery process (OGP, 2008)

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The NORM nuclides of primary concern in oil production are Radium-226 and Radium-228.

These decay into various radioactive progeny, before becoming stable lead.

Other radionuclides such as Lead-210 and Polonium-210 can also be found in pipeline

scrapings as well as sludge accumulating in tank bottoms, separators, tanks and waste pits.

Radon-222 is a radioactive gas, which is present in varying degrees in natural gas in oil & gas

formations. In the absence of natural gas, radon dissolves in the (light) hydrocarbon and

aqueous phase. When produced with the oil and gas, radon will usually follow the gas stream.

5.2

Monitoring for NORM

Due to the fact that NORM can occur in numerous locations, it is important to test all

equipment which has been in contact with fluids of any sort for NORM contamination before

work commences. This applies to work involving maintaining, repairing or exposing internal

surfaces of the oil and produced water process (vessel entry, pipework systems, tubulars, etc).

It also applies to seawater systems, as seawater contains trace levels of Lead-210 and

Uranium-238, which can be deposited as a radioactive film when large quantities of seawater

pass through any plant or equipment. Pipeline pigs and debris from pigging operations should

also be routinely checked for NORM contamination.

The presence of NORM within well and process equipment is identified by the use of site

contamination monitors. Contamination checks are only carried out by the site RPS, or by an

Authorised Monitor User (i.e. someone who has received appropriate training).

Guidance on the proper use of radiation monitoring instruments and the correct interpretation

of results, is provided in Appendix F of the AzSPU Procedure for Management of Radioactive

Materials & Radiation Generators (AzSPU-HSSE-DOC-00058-2). Specific information on the

method for conducting contamination monitoring of tubulars is provided in Appendix A.

The site RPS, or Authorised Monitor User, will consider a

“sustainable rise above

backg2round” as a sign of contamination when monitoring items or material.

The NORM Contamination Monitoring Log (Appendix B) must be completed each time a

check is made, even if the result is negative.

If a positive result is found then a NORM Survey Report (Appendix C) must be completed

and the report given a unique reference number.

If the contaminated material / equipment is to be disposed of, the site RPS will then collect

samples (in accordance with Appendix D) and ensure that they are sent to a specialist

laboratory for analysis, i.e. the Tracerco laboratory in Billingham (contact details provided in

Appendix B of the AzSPU Procedure for Management of Radioactive Materials & Radiation

Generators (AzSPU-HSSE-DOC-00058-2)). Details of the samples will be recorded in the

NORM Sample Register (Appendix E).

The RPA will use the analysis results to determine whether the material is Exempt or not (see

Section 3) and will advise the site RPS accordingly (through the AzSPU RP SPA). A record of

the weight of material, together with the analysis results, will be used to record the actual

activity of the material that is to be disposed of.

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5.3

Preparation for Work Involving NORM

5.3.1 Risk Assessment

A generic risk assessment for work with NORM will be maintained by the RPS in the Site

Radiation Records. Task or job specific risk assessments will also be carried out, using the

generic risk assessment as a basis.

5.3.2 Training

All persons involved in work with NORM must have received radiation awareness training.

Normally this will involve a one day NORM Awareness Training Course, however, the RPS

may carry out on-site training provided this covers the hazards and risks associated with

exposure to NORM and the control measures to keep exposures as low as reasonably

practicable. In addition, the Site RPS will ensure that all persons working with NORM are

aware of and understand the relevant parts of this procedure.

The RPS will ensure that records of all training are kept in the Site Radiation Records.

5.3.3 NORM Handling Materials

All sites must have a stock of basic NORM handling materials, namely NORM tape,

polythene sheeting and sample pots. If well work is being carried out (which involves pulling

tubing) then sufficient end caps and polythene sleeves must also be available.

5.3.4 Personal Protective Equipment

There are two ways in which personnel can be exposed to NORM, namely:

 External exposure - where the radioactive material remains outside the body.

 Internal exposure - where radioactive material is taken into the body via inhalation,

ingestion or absorption.

All persons carrying out work where NORM may be present must wear the following PPE as

a minimum:

 Impervious overalls that can be easily decontaminated e.g. one-piece slicker suits.

 Impervious boots and gloves.

 A filtering face piece respirator with P3 filter for work with small quantities in

Supervised Areas. Or a „face fitted‟ respirator to EN149FFP - P3 rated as minimum

(e.g. 3M 8835, Moldex 3405 or Draeger Piccola FFP3-V type) for work in Controlled

Areas. All respirators must be „CE‟ marked and consideration must also be given to

the presence of other hazards that may require a COSHH assessment to be carried out.

For „heavy work‟, or work in areas where other hazards exist, it may be appropriate to

use air-fed breathing apparatus.

 Eye protection goggles.

All open wounds must be dressed with water proof dressings prior to any work with NORM.

No smoking, eating, drinking, chewing of gum, sweets or tobacco or application of barrier

cream, e.g. lip salve, is permitted by any individual whilst engaged in any operation where

NORM scale is being handled.

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Any individual involved in a NORM operation must decontaminate himself prior to leaving

the worksite by wiping down or showering/hosing with water, with particular attention being

paid to boots and gloves. Personnel must be monitored by the site RPS to confirm that the

decontamination procedure has been effective.

Personal protective equipment may be kept for reuse provided it has been decontaminated.

5.3.5 Breaking Containment

Prior to breaking containment, a Supervised Area will be designated and heavy-duty

polythene sheeting used to cover the deck within the whole Supervised Area, or at least in

areas where scale may fall. Drains will also be covered.

Personnel entering the Supervised Area will wear appropriate PPE, and will monitor for

NORM contamination once the equipment has been opened. If a “sustainable rise above

backg2round” is recorded a Controlled Area will be established.

The Controlled Area will be marked by barriers and tape, with signs stating that it is a NORM

Controlled Area and that entry is restricted. All NORM handling procedures must be enforced

within this area, e.g. protective clothing must be put on at the entry point and removed and

decontaminated at the exit point. Entry must be restricted to people directly involved in the

work.

If removal of NORM waste from the vessel / equipment is required, samples of NORM scale,

sludge, etc will be obtained in accordance with Appendix D and sent to the Tracerco

laboratory in Billingham.

Removal and storage of NORM waste from the vessel / equipment will be carried out in

accordance with Section 5.4 and the equipment closed up.

When the work is complete, a contamination check will be made of the Controlled Area. The

area will be cleaned down, and the deck below the polythene sheeting checked for

contamination.

The RPA will advise on transportation and disposal requirements for the NORM waste

(through the AzSPU RP SPA), based on the results of the sample analysis.

A flow chart summarising this process is provided in Figure 2.

5.4

Storage Arrangements for NORM Contaminated Material

Storage arrangements for NORM contaminated material will meet the following general

requirements:

 Only suitably qualified and experienced persons (RPS and those who have had

appropriate training) shall have access to the radioactive waste (with measures taken

to prevent access by others).

 The premises where radioactive waste is being accumulated shall be constructed and

maintained in such a way and condition that they can be easily decontaminated.

 The storage area will provide protection from the effects of the weather.

Control Tier: 2

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Figure 2: Breaking Containment - Vessel Entry

Prior to breaking containment

designate a Supervised Area,

put down polythene sheeting,

and wear appropriate PPE.

Open equipment. Monitor for

NORM contamination.

Is there a

Keep monitoring

sustainable rise

throughout. De-designate

above backg2round?

if nothing detected.

Yes

Elevate to a Controlled Area.

Close up equipment

Does work require removal and

following

disposal of NORM waste?

maintenance.

Yes

Obtain samples of NORM scale,

sludge, etc in accordance with

Appendix D and send to lab.

Remove NORM scale, sludge,

etc from vessel and store in

accordance with Section 5.4.

Close up equipment.

RPA will advise on

transportation requirements and

disposal route, based on results

of sample analysis.

Control Tier: 2

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5.4.1 Handling

Bulk Material

Contaminated bulk material must be placed in good quality steel drums with secure lids. The

drums will be no more than three quarters filled and bulk material should be contained within

sealed heavy-duty polythene bags within the drums.

The site RPS, or other nominated person, will check the drums for external contamination, and

if any contamination is found it will be removed fully by wiping with a rag. Contaminated

rags will also be placed in the drums.

Contaminated Equipment

Contaminated equipment will be immediately secured in such a way as to prevent spread of

contamination to other items, work areas or personnel.

Any item contaminated internally will be sealed to prevent contamination from escaping e.g.

contaminated tubulars will be sealed with end caps, and the seals wrapped with polythene and

taped.

Contaminated items must not be allowed to dry out in the atmosphere. They must either be

suitably sealed, or kept moist.

Tubulars will be stored in bundles, or stows, and not directly placed on the ground. If there is

a possibility that weather could affect the integrity of the containment measures then

additional protection will be provided, e.g. wrapping of tubular bundles in heavy duty

polythene sheeting that is secured in place.

Items other than tubulars will be placed in fully sealable containers, or units that can be

covered.

Any pieces of scale falling out of contaminated equipment / tubulars must be inserted back

into the equipment which will then be sealed / capped.

Items that are externally contaminated will be wrapped in heavy-duty polythene sheeting (to

ensure total enclosure) and taped.

A flow chart summarising the handling of NORM contaminated equipment is provided in

Figure 3.

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Figure 3: Handling of NORM Contaminated Equipment and Tubulars

Monitor for

Is there a

Equipment,

No action required.

pipe work,

NORM

sustainable rise

tubulars, etc.

contamination

above

on internal and

backg2round?

external

surfaces.

Yes

Is the

Subsequent

equipment to be

handling of

scrapped or

equipment should be

sent onshore for

carried out using

storage?

appropriate PPE.

Yes

Do you have time

Yes

and space to take

samples and send

to lab?

Transport equipment,

Obtain samples in

pipe work, tubulars, etc,

accordance with

in such a way as to

Appendix D and send

prevent spread of

to lab

contamination *

RPA will advise on

transportation

Store equipment,

requirements and

pipework, tubulars, etc

disposal route, based

temporarily at Supply

on results of sampling

Base

analysis.

* Must meet specifications listed in Section 5.2 of the AzSPU Procedure for Transportation of Radioactive

Materials if being sent unpackaged.

5.4.2 Marking and Labelling of NORM Contaminated Material

Bulk Waste

A label with the legend “Radioactive” and the radiation trefoil will be attached to each drum.

The label will include details of the name of the site, the origin of the waste, the date produced

and a unique reference number. The unique reference number must be traceable to samples or

a sample reference number for the waste. The label will also be marked “Solid Waste”,

“Contaminated Fluids” or some other appropriate description of the form of the waste.

Contaminated Items

Each contaminated item will be identified with yellow / black NORM tape and a suitable,

indelibly marked label or marking on the item stating „Radioactive NORM”. Items will be

marked with name of the site, date produced and a unique reference number, which will be

used for other documentation relating to the particular waste.

In terms of contaminated tubulars, each joint must be identified with its well and tubing string

number, which should be painted on the joint where possible.

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When transporting contaminated tubulars in bundles, NORM tape must be wrapped round the

legs of the sling to aid identification. Individual tubulars should also be marked. Do not tape

complete bundles as the tape inevitably breaks and falls off in transit.

The total activity of the waste on each item will be estimated using average contamination

measurements in Bq/cm² and multiplying this by the estimated surface area covered by the

waste in cm², to give a figure in Bq.

5.4.3 NORM Storage Areas

Drums of NORM, or wrapped contaminated items, will be stored in a skip or bunded area

with tarpaulin or some other form of cover. This area should also be barriered and access

restricted to authorised persons only i.e. persons involved with NORM work.

Offshore, if deck space is short and larger items cannot fit in a waste store, then any temporary

storage area must be secure and procedures in place to control access.

Only NORM waste may be stored in the NORM storage area and it must be ensured that the

storage area is away from other major hazards such as explosives or corrosives.

Warning signs must be displayed around the NORM storage area with the radiation trefoil

symbol and the legend “Radioactive. NORM Storage Area. No Unauthorised Access”.

The OIM/Site Manager, with the assistance of the site RPS, will ensure that the waste is

transferred from site as soon as reasonably practicable (see Section 5.5). Waste will normally

be transferred within three months of being accumulated. If this is not practicable then the

OIM must review the situation and ensure that arrangements are made for the waste to be

transferred within six months of being accumulated. If this cannot be achieved then the

AzSPU Radiation Protection SPA and the RPA will be consulted.

Dose rate monitoring must be carried out around bulk accumulations and around contaminated

equipment stows. If the dose rate exceeds 7.5 µSv/h at 30 cm from drums, or stows then a

Controlled Area must be designated and appropriate barriers and signage in place.

NB: If storage of NORM waste is initiated on-site, the AzSPU Radiation Protection SPA

needs to be notified immediately so that a „Special Permission‟ can be obtained from the

MENR.

5.4.4 Records & Inspection

The site RPS will ensure that details of all NORM waste being accumulated and stored are

added to the Waste Accumulation and Storage Record (Appendix F).

The inventory of waste items will be checked on a regular basis, e.g. weekly, by the site RPS.

At the same time the storage arrangements will be reviewed to ensure they remain adequate.

Control Tier: 2

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Document Number: AZSPU-HSSE-DOC-00097-2

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5.5

Transportation & Disposal of NORM Contaminated Equipment and

Waste

The transportation and disposal requirements for NORM contaminated equipment and waste

are dependent on whether the waste is classed as Exempt, in accordance with the IAEA

specifications (see Section 3).

Exemption is the determination by a regulatory body that a source or practice need not be

subject to some or all aspects of regulatory control, on the basis that the exposure (including

potential exposure) is too small to warrant the application of the requirements.

The RPA (through the AzSPU RP SPA) will advise on the transportation and disposal

requirements, based on the results of the sampling and analysis.

The AzSPU Procedure for Transportation of Radioactive Materials (AzSPU-HSSE-DOC-

00115-2) provides further detail on transportation of NORM contaminated waste and

equipment, and NORM samples.

Key Documents/Tools/References

This document shall, where appropriate, be used in conjunction with of the following

procedures and plans:

Document Number

Title of Procedure

AzSPU-HSSE-DOC-00058-2

Procedure for Management of Radioactive Materials

and Radiation Generators

AzSPU-HSSE-DOC-00115-2

AzSPU Procedure for Transportation of Radioactive

Materials

AzSPU-HSSE-DOC-00086-2

AzSPU Radiation Contingency Plan

AzSPU-HSSE-DOC-00083-2

AzSPU Procedure for The Import / Export of

Radioactive Materials and Sources of Ionising Radiation

AzSPU-HSSE-DOC-00025-2

AzSPU HSSE Document Management Procedure

AzSPU-HSSE-DOC-00021-2

AzSPU HSSE Definitions

References:

OGP (International Association of Oil and Gas Producers),

2008. Guidelines for the

Management of NORM in the Oil and Gas Industry. Report No. 412.

Revision/Review Log

Revision Date

Authority

Custodian

Revision Details

7^th October, 2009

Yuliy Zaytsev (Safety

Idrak Nazarov (HSE

Initial Issue.

& Compliance

MS Team Leader)

Manager)

Control Tier: 2

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Appendix A - NORM Monitoring of Tubulars

Well control equipment and tubulars that have been used to produce reservoir fluids have the

potential to be contaminated with NORM, monitoring will therefore be carried out during the

drilling operation by the site RPS, or an Authorised Monitor User.

Initial Actions

 A supply of tubing end caps will be on hand for sealing the complete string in the event

that contamination is found and it is to be removed from the well.

 Heavy duty polythene sheeting and sleeves will be provided for wrapping externally

contaminated items.

 The drill floor will be designated a Supervised Area if contamination is detected and

access will be restricted. Personnel at risk of exposure will wear suitable PPE (see Section

5.3.4) and appropriate washing and changing facilities will be provided at the entry to the

area. If there is a significant risk that contamination may be spread, then the area

designation will be elevated to a Controlled Area.

Identification of NORM Contamination

The site RPS, or an Authorised Monitor User, will monitor all well control equipment (e.g.

tubing hangers, down-hole safety valves) as they are removed, ensuring all accessible internal

surfaces are monitored. If contamination is detected, open flanges must be sealed with flange

protectors or heavy-duty polythene sheeting and secured with NORM tape.

If contamination is later detected on the tubing string then it must be assumed that down hole

valves and pumps are internally contaminated, unless they have been monitored internally and

shown to be clean.

As the tubing string is pulled, the first five joints will be monitored for contamination and if

none is found then every tenth joint thereafter will be monitored. If a contaminated joint is

found, then all joints up to the last one to have been monitored, will be checked. All

subsequent joints will then be monitored.

All monitoring outcomes must be recorded on the NORM Contamination Monitoring Log

(Appendix B). In the event that contamination is found, then a NORM Survey Report

(Appendix C) must be completed.

If the tubulars are to be reused, subsequent handling must be carried out using appropriate

PPE. If the tubulars are to be scrapped, sampling and analysis must be conducted prior to

disposal.

Monitoring of Logging Tools

Some logging tools contain radioactive sources. Monitoring should only be carried out prior to

sources being loaded into the tools or after the sources have been removed.

In addition, some logging tools that use neutron generating devices can become „activated‟ i.e.

the casing of the tool becomes radioactive (note, not contaminated) for a period of time after

the tool has been energised. If a tool could have been activated during operation then it should

be isolated for several hours after retrieval and then checked. If contamination is apparently

detected then the tool should be left for around 1 hour to see if the contamination level

decreases. Only then should a decision be made as to whether it is contaminated or not.

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Appendix C - NORM Survey Report

Installation:

Report No.:

Plant

Plant I.D.

Description

No.

Monitor

Type:

Serial

No.:

No. of

Reason if

samples

none:

Sample references

Comments:

Vessels

Reason for Survey

Pre-entry check

Pre-cleaning check

c.p.s

Bq/cm²

µSv/h

Monitoring Results

Estimated Volume

Estimated

Quantity of Material (scale,

(m³)

Weight (kg)

Thickness (mm)

sand, sludge, other etc)

Action Taken

Not Removed

Storage

Discharged

Comments

Spools / Valves / Other

Removed for Repair

Removed for Cleaning

Reason for Survey

Removed to Replace

Other

c.p.s

Bq/cm²

µSv/h

Monitoring Results

Estimated Volume

Estimated

(m³)

Weight (kg)

Thickness (mm)

Quantity of Scale etc.

Return to Service Uncleaned

Action to be Taken

Clean Offshore Return to Service Scrap Item

Clean Onshore Return to Service Scrap Item

Comments

Production Tubing / Downhole Equipment

Reason for Survey

Renewal

Workover

Other

(i.e. reason removed)

c.p.s

Bq/cm²

µSv/h

Monitoring Results

External Scaling

Yes No

Return Downhole Uncleaned

Action to be Taken

Clean Onshore and Re-use

Clean Onshore and Scrap

Comments

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Appendix D - Sampling Protocol for NORM

Introduction

If a positive sustainable rise above backg2round is observed during radiation monitoring then

representative sampling should be conducted (if the intention is to dispose of the contaminated

equipment, NORM scale, etc). The activity concentration of NORM materials can only be

determined by radiochemical analysis.

The site RPS will conduct any required sampling as follows:

Process Vessels

Where progress through a vessel can be made on entry, an initial contamination survey will be

conducted under the supervision of the site RPS.

Where a positive sustainable rise above backg2round is observed, samples of materials (e.g.

sand, sludge, scale) will be taken. The number of samples required of each form of material

will be determined by the RPS, based on the quantity of material and the range of

contamination monitor readings obtained.

Samples will be taken from the front, middle and back of the vessel - five samples from each

area. These will then be aggregated for each area and a representative sample taken from each

and sent for radiochemical analysis (3 samples in total).

Sample sizes should meet the following criteria for the purposes of transportation:



1-4 samples - maximum weight per sample 50g.



5-8 samples - maximum weight per sample 25g.

Where progress through a vessel is determined by the progressive removal of internal fittings,

monitoring will be carried out whenever a new internal surface is exposed. Representative

sampling will also be done at each stage if recordings above backg2round are detected, again

paying attention to possible different forms of the material. Where considered appropriate by

the RPS, on the basis of the contamination readings observed, such samples may be

aggregated and a representative sample analysed.

Tubulars

In order to obtain a sample, scrape approximately 25 - 50g of material into a small container

(e.g. 100 ml sample pot with screw lid) using a spatula or other suitable tool. Fix a lid on the

container and add tape to the seal to prevent leakage. The RPS should ensure that

representative samples are taken from the batch of tubulars e.g. a sample from the most

contaminated, the least contaminated, and those in between.

Pigging Wax

If a positive sustainable rise above backg2round is observed whilst monitoring pigging wax, at

least two 50 g representative samples will be required from each drum of wax. The volume of

wax must be recorded.

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Contaminated PPE

PPE that has been cleaned but which still retains activity levels above backg2round should be

placed in sealed drums and a representative sample taken. The RPS shall identify the

contaminated PPE which gives the highest counts per second (cps) on the contamination

monitor, remove a section and place into a 50g sample pot.

Sample Storage

Samples should be placed in a secure container (sample pots can be obtained from the

Tracerco laboratory), with the lid sealed with tape and labelled to indicate the radioactive

nature of the material, the date, origin and site. Unless being immediately despatched, the

samples will be securely held by the site RPS, or other Authorised Person, in a suitable store,

labelled with the radiation trefoil and the legend „Radioactive‟.

Transport of Samples

All samples are to be sent for analysis to the Tracerco laboratory in Billingham (address

provided in Appendix B of the AzSPU Procedure for Management of Radioactive Materials &

Radiation Generators (AzSPU-HSSE-DOC-00058-2)).

Section 5.3 of the AzSPU Procedure for Transportation of Radioactive Materials (AzSPU-

HSSE-DOC-00115-2) provides more detail on how to transport NORM contaminated

samples.

Records

Details of all samples taken and sent for analysis will be added to the site NORM Sample

Copies of the sample analysis results will be filed in the Site Radiation Records and must be

kept for five years.

The weights of the material to be disposed of will be calculated by direct measurement or by

volume calculations. AzSPU has the responsibility of ensuring that there is some way of

documenting how the weights were arrived at.

Control Tier: 2

Initial Issue:

7 October, 2009

Document Number: AZSPU-HSSE-DOC-00097-2

Print Date: 2/1/2011

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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators

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AzSPU Procedure for

Management of Radioactive Materials and

Radiation Generators

AzSPU-HSSE-DOC-00058-2

Authority:

Yuliy Zaytsev (AzSPU

Custodian:

John Elliott (AzSPU Senior HSE Advisor)

Safety & Compliance

Manager)

Scope:

AzSPU

Document

AzSPU HSSE MS Document Co-ordinator

Administrator:

Issue Date:

20 October 2004

Issuing Dept:

AzSPU HSSE

Revision Date:

04 October, 2010

Control Tier:

2- AzSPU

Next Review

04 March, 2011

Date:

TABLE OF CONTENTS

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

Document No: AzSPU-HSSE-DOC-00058-2

Print Date: 2/1/2011

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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators

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Purpose/Scope

Definitions

General Requirements

3.1

Legislative Requirements

3.2

AzSPU Ionising Radiation Policy

Key Responsibilities

Procedure

5.1

Radiation Protection Programme (RPP)

5.1.1

Designation of Controlled & Supervised Areas

5.1.2

Radiation Procedures and Radiation Protection Supervisors

5.1.3

Monitoring of Workers, the Workplace, and Radiation Monitoring Equipment

5.1.4

Recording and Reporting Monitoring Information

5.1.5

Provision of Training to Persons Involved in Work with Ionising Radiation

5.1.6

Periodic Reviews / Audits of Performance and Compliance

5.1.7

Provision of Contingency Plans to Address Incidents / Accidents

5.1.8

Provision of a Health Surveillance Programme

5.2

Management of Contractors Working With Ionising Radiation

5.2.1

Management Arrangements

5.2.2

Responsibilities

5.2.3

Contractor’s Arrangements for Managing Work with Ionising Radiation

5.2.4

Completion of Contractor’s Checklist by AzSPU Site RPS

5.2.5

General Arrangements for Managing Contractor Sources on Site

5.3

General Work Instructions for Working with Ionising Radiation

5.4

Work Instructions for Site Radiography

5.5

Work Instructions for Well Logging

5.6

Work Instructions for the Storage and Use of Pip Tags

5.7

Work Instructions for Nucleonic Devices

5.7.1

Management Arrangements

5.7.2

Critical Examination on Installation

5.7.3

Controlled and Supervised Areas

5.7.4

Site Register of Installed Sources

5.7.5

Source Accounting

5.7.6

Radiation Monitoring

5.7.7

Maintenance and Safety Checks

5.7.8

Leakage Testing

5.7.9

Entry to Vessels Fitted with Nucleonic Devices

5.7.10

Precautions for Vessels Incorporating Nucleonic Interface Gauges

5.7.11

Removal of an Installed Nucleonic Device

5.7.12

Temporary Storage of Nucleonic Devices

5.7.13

Source Disposal

Key Documents/Tools/References

Control Tier:

2-AzSPU

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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators

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Appendices

Appendix A Definitions

Appendix B Qualified Expert / Radiation Protection Adviser Contact Details

Appendix C Controlled Area Handover Certificate

Appendix D Record of Entry into a Controlled Area

Appendix E Radiation Exposure Log

Appendix F Radiation Monitoring

Appendix G Site Radiation Monitoring Equipment Register

Appendix H Critical Examination Checklist

Appendix I

Radioactive Source Accountancy, Monitoring and Safety Checks

Appendix J

Leakage Test Method

Appendix K

Procedure for Isolating and De-isolating Sources in Dip-pipes

Appendix L

Procedure for Isolating and De-isolating Profiler Sources

Appendix M

Contractors Checklist for Contractors Using Radioactive Materials on

AzSPU Sites

Appendix N Site Mobile Source Register

Appendix O Site Inaccessible Source Register

Appendix P References

Control Tier:

2-AzSPU

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Purpose/Scope

Azerbaijan Strategic Performance Unit (AzSPU) has a responsibility to ensure that all work

with ionising radiation, including the use of radioactive materials and radiation generators, is

carried out in accordance with applicable national and international legislation and standards.

The purpose of this document is therefore:

 to define the AzSPU‟s Ionising Radiation Policy, the aims and objectives of which are to

ensure that all work with ionising radiation is carried out in accordance with applicable

national and international legislation and standards.

 to describe how the Policy objectives will be achieved through a Radiation Protection

Programme; and

 to provide detailed information and procedures relating to radiation safety.

This controlled procedure applies to AzSPU Operations PUs and Projects engaged in the

drilling, production, and/or transportation of oil and gas (including support activities), and

construction activities when working with ionising radiation in Azerbaijan. Contractors

working on AzSPU owned or operated sites/installations are also required to align with this

procedure.

This procedure is written in sufficient detail to enable it to be applied consistently at all sites

or installations. There may still be the requirement for some site-specific instructions covering

logistical & administrative arrangements, and site-specific variations in responsibilities to

reflect differences in organisational arrangements. These site-specific instructions should not

deviate from the core processes within this document. Any form of deviation from this

procedure, including but not limited to site-specific instructions, shall be requested and

authorised in accordance with the AzSPU Deviations Procedure (AzSPU-HSSE-DOC-00011-

2).

Revision of this procedure and the operational controls detailed therein will be in accordance

with the AzSPU HSSE Document Management Procedure (AzSPU-HSSE-DOC-00025-2).

Definitions

Refer to document AzSPU HSSE Definitions AzSPU-HSSE-DOC-00021-2 for definitions

common to this HSSE&S MS. Definitions specific to this procedure are included in

Appendix A.

General Requirements

3.1

Legislative Requirements

The principle piece of legislation in Azerbaijan is the Law of the Azerbaijan Republic on

Radiation Safety of the Population, No. 423IQ, 30^th December, 1997. Article 3 of the Law

lists the Basic Principles for Ensuring Radiation Safety. These principles are based on, or

have parallels with, the basic principles of Justification, Optimisation and Dose Limitation, as

recommended by the International Atomic Energy Agency in Safety Series 115 „International

Control Tier:

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AzSPU Procedure for Management of Radioactive Materials & Radiation Generators

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Basic Safety Standards for Protection Against Ionising Radiation and for the Safety of

Radiation Sources‟ (IAEA, 1996).

The IAEA principles in Safety Series 115 (SS115) are summarised here:

Justification (Substantiation)

No practice involving exposure to radiation should be adopted unless it produces at least

sufficient benefit to the exposed individuals or to society to offset the radiation detriment

caused.

Optimisation (Intimation)

All exposures shall be kept As Low As Reasonably Practicable (ALARP), economic and

social factors being taken into consideration.

Dose Limitation (Standardisation)

The doses received by individuals from practices involving radiation, should not exceed the

relevant limits specified by the Regulatory Authority.

The dose limits specified in SS115 dose limits, Schedules II-5, II-6 and II-8 are:

Annual Dose Limits

Workers

Public

Trainees

Whole Body Effective Dose

20 mSv

1 mSv

6 mSv

Lens of the eye (Equivalent dose)

150 mSv

15 mSv

50 mSv

Extremities (hands and feet) or skin

500 mSv

50 mSv

150 mSv

In the special case of female workers, the worker must notify management on becoming

aware that she is pregnant so that the worker‟s working conditions can be reviewed. A dose

limit of 1 mSv to the embryo or foetus will be applicable in this situation.

3.2

AzSPU Ionising Radiation Policy

AzSPU is committed to a policy of restricting exposure to ionising radiation in accordance

with the ALARP principle and ensuring that dose limits are not exceeded. This principle will

be applied in all situations involving work with ionising radiation, whether the work is carried

out by AzSPU, or by contractors operating on AzSPU sites. AzSPU will affect this through

the implementation of the organisational arrangements and responsibilities detailed in the

Radiation Protection Programme (see Section 5.1). AzSPU will also take all reasonably

practicable steps to protect the environment from discharges and disposal of radioactive

waste.

AzSPU will comply with all applicable national and international legislation. Account will

also be taken of international standards in radiation protection, such as may be issued

periodically by the International Atomic Energy Agency. In all situations the objective will

be to provide the highest standard of radiation protection.

AzSPU shall ensure that workers exposed to radiation from sources, other than natural

sources, that are not directly related to their work or not required by their work, receive the

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same level of protection as if they were members of the public. This in effect applies a dose

limit of 1 mSv to individual members of the general workforce who are not involved in

work with ionising radiations, but who may be exposed as a result of ongoing work with

ionising radiation.

Furthermore, AzSPU will ensure that the use of radioactive materials and radiation generators

in equipment or processes, or by third party contractors is subject to a justification process.

This will be a relatively simple and straightforward process for common practices such as the

use of nucleonic instrumentation, well logging and radiography (both X and gamma), where

the justification for the use of radiation sources over other methods is well established. For

most other industrial uses of radioactive materials or radiation generators, the justification

process should again be relatively straightforward, providing consideration has been given to

alternative methods or technologies and that the radiation doses that are likely to be received

by affected personnel will not be significant and that there are clear advantages in terms of

cost and resources. However, cost alone should not be the only reason for ruling out

alternatives that do not involve radioactive materials or radiation generators.

In the event that the use of radioactive materials or radiation generators cannot be easily

justified, then the Radiation Protection Adviser (RPA) should be contacted for advice.

It will not normally be necessary to restrict exposure from routine operations

(unless

otherwise identified by a risk assessment), however, pregnant workers will not be allowed to

work with unsealed radioactive materials, including NORM.

These policy goals will be achieved by implementing a Radiation Protection Programme

(Section 5.1), the main elements of which are as follows:

 Assigning responsibilities for occupational radiation protection and safety;

 Designating controlled or supervised areas;

 Providing procedures, local rules, work instructions, etc for workers to follow and

appointing individuals to supervise work with ionising radiation;

 Monitoring workers and the workplace as appropriate, including the acquisition and

maintenance of radiation monitoring instruments;

 Recording and reporting all the relevant information related to the control of exposures,

the decisions regarding measures for occupational radiation protection and safety, and the

monitoring of individuals;

 Providing suitable and sufficient training to all persons involved in work with ionising

radiation;

 Carrying out periodic reviews / audits of performance and compliance;

 Providing contingency plans to address accident situations;

 Providing a health surveillance programme for certain individuals as appropriate.

Key Responsibilities

AzSPU Azerbaijan Leadership Team (ALT)

The ALT is ultimately accountable for ensuring that all radiation exposures are as low as

reasonably practicable (ALARP) and for ensuring that dose limits are not exceeded. They are

also accountable for ensuring that the requirements of applicable national and international

legislation are met.

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

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Although these responsibilities cannot be delegated, AzSPU ALT will aim to fulfil their

responsibilities by implementing the following organisational arrangements and

appointments.

AzSPU HSE & Technical Vice-President / AzSPU Safety & Compliance Manager

AzSPU HSE & Technical Vice-President / AzSPU Safety & Compliance Manager are

accountable and responsible

(respectively) for ensuring that suitable organisational and

procedural arrangements are in place in order that the AzSPU Radiation Protection

Programme can be implemented.

In addition they are accountable / responsible for:

 Appointing an AzSPU Radiation Protection Single Point Accountability (RP SPA).

 Appointing a suitable Qualified Expert / Radiation Protection Adviser (RPA) to provide

advice to AzSPU SPA on radiation safety matters and legal compliance issues and to

ensure that all work with ionising radiation at AzSPU sites is audited on a regular basis.

AzSPU Radiation Protection Single Point Accountability (RP SPA)

The RP SPA occupies a central HSE role and resides in the AzSPU Safety & Compliance

Team covering Onshore and Offshore Operations, Drilling, Completion & Intervention

(DC&I), as well as major projects. The duties of the RP SPA are summarised as follows:

 Ensuring that the AzSPU Procedure for Management of Radioactive Materials and

Radiation Generators is reviewed on a regular basis.

 Providing internal coordination between PUs and departments to ensure alignment of

processes and practice.

 Ensuring that internal monitoring is in place and carried out on regular basis.

 Providing contractor management.

 Maintaining proper communication flow between the RPA (UK based) and the AzSPU

Radiation Protection Supervisors (RPSs).

 Coordination of radiation protection audits.

 Liaising with government bodies regarding radiological protection issues, if required.

 Ensuring timely development of required reports, if any.

 Supporting investigations into radiation related issues.

AzSPU Radiation Protection Adviser (RPA) / Qualified Expert

AzSPU will retain, by contract and appointment, Radiation Protection Advisers (also called

Qualified Experts) to provide the AzSPU with expert advice on radiation safety and to advise

on compliance matters. The RPA will report to the AzSPU Safety & Compliance Manager

and work directly with the AzSPU RP SPA. Contact details for the RPA‟s are provided in

Appendix B.

An important part of the RPA‟s role will be to carry out a review of all activities involving

ionising radiation at AzSPU facilities to determine whether associated exposures are ALARP.

Audits will be carried out to this end, the frequency of which will be determined by the

AzSPU Safety & Compliance Manager, in agreement with the Offshore & Onshore PULs and

DC&I & MPPU VPs. Matters on which the RPA should be consulted are:

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 Radiation risk assessment;

 Radiation procedures;

 Emergency response plans;

 Methods for restricting exposure;

 Designation of areas;

 Training;

 Radiation monitoring and selection and calibration of radiation monitoring equipment;

 Maintenance of engineering controls;

 Dose assessment and recording;

 Investigations into doses in excess of the investigation level;

 Investigation of accidents.

AzSPU Safety & Compliance Team

AzSPU Safety & Compliance Team is responsible for identifying and communicating current

applicable legislation for work involving ionising radiation, and for maintaining the

Compliance Task Management (CTM) database.

Site Manager / Offshore Installation Manager (OIM)

The Site Manager / OIM is accountable for all aspects of radiation safety on any site under his

control or authority. He will ensure that the radiation procedures are implemented and that

suitable local arrangements are made to achieve the AzSPU‟s Ionising Radiation Policy goals.

In particular he is accountable for ensuring that:

 Suitable persons have been appointed to supervise work with ionising radiation i.e.

Radiation Protection Supervisors (RPSs) and that a Site Register of RPSs is kept.

 All persons involved in work with ionising radiation have received adequate training and

details of their training are recorded.

 The radiation procedures and site-specific instructions are made available to those

persons who are affected by them.

 Suitable and sufficient radiation monitoring instruments are provided.

 Prior to any work with ionising radiation, a risk assessment is carried out.

 Suitable and sufficient personal protective equipment is provided, as and when necessary,

for the prevention of contamination of personnel.

 Suitable and sufficient work equipment and facilities are provided for all work with

ionising radiation.

 Suitable records are kept with details of the radioactive substances that are used or stored

on site, or that are disposed of from site i.e. the Site Radiation Records.

Radiation Protection Supervisors (RPSs)

The Site Manager / OIM will appoint RPSs to ensure that, on a day to day basis, all work is

carried out and supervised in accordance with AzSPU procedures, site-specific instructions,

etc. Specific duties of the RPS are:

 To ensure that all work with ionising radiation is subject to a radiation risk assessment.

 To implement Contingency Plans for incidents or accidents involving work with ionising

radiation.

 To be a first point of contact for all persons with concerns regarding radiation protection

on site.

Control Tier:

2-AzSPU

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 To liaise with the Site Manager / OIM regarding radiation protection issues and the

implementation of the radiation procedures.

 To maintain the Site Radiation Records.

 To assist and participate in radiation safety audits organised by AzSPU RP SPA and

conducted by the RPA.

 To ensure that any work with radioactive substances, carried out by contractors, is in full

compliance with the requirements of their radiation procedures or site-specific

instructions.

AzSPU Permitting and Regulatory Affairs / AzSPU Central Environmental Team

AzSPU Permitting and Regulatory Affairs are responsible for liaising with regulatory bodies,

e.g. Azerbaijan Ministry of Emergency Situations (MES), regarding permitting and licensing

issues. AzSPU Central Environmental Team is responsible for liaising with Azerbaijan

Ministry of Ecology and Natural Resources (MENR).

Authorised Persons

Personnel may be appointed to carry out specific tasks included in this procedure. These

individuals will be authorised by the Site Manager / OIM to carry out those tasks provided

they have attended a suitable radiation awareness course, appropriate to the task involved.

Training records and a Register of Authorised Persons will be maintained in the Site

Radiation Records. Examples of tasks for which Authorised Persons may be appointed are

routine radiation monitoring and safety checks around fixed nucleonic sources and

contamination (NORM) checks.

Workers

All workers are responsible for the safety of themselves and others who may be affected by

their actions or inactions. In particular, all workers are required to:

 Follow any applicable procedures or local rules relating to radiation protection or safety.

 Use monitoring devices and personal protective equipment and clothing provided.

 Comply with any dose assessment or health surveillance programmes.

 Provide AzSPU with information about previous occupational exposure to ionising

radiation.

 Refrain from any actions that will cause unnecessary exposure of themselves or others.

 Take appropriate actions to ensure their personal exposure to radiation is ALARP,

through using safe working practices on which they are trained.

 Accept information, instruction and training on radiation protection and safety that will

enable them to carry out their work in accordance with the radiation procedures or local

rules.

In addition, female workers will have the responsibility of informing management when they

know, or suspect, that they are pregnant.

Contractors

All third party contractors working with radioactive sources or radiation generators on

AzSPU sites will be required to work according to this procedure and in compliance with

applicable national and international legislation. In all cases third parties will have appointed

a Radiation Protection Officer (RPO) to supervise their work. The Contractor RPO will be

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responsible for ensuring that all work is carried out in accordance with this radiation

procedure, or site-specific instructions, and meets the requirements of applicable national and

international legislation.

Procedure

5.1

Radiation Protection Programme (RPP)

5.1.1 Designation of Controlled & Supervised Areas

As a means of restricting radiation exposure, work areas will be designated as either

„Controlled‟ or „Supervised‟.

In determining whether an area should be categorised as Controlled or Supervised, the

following criteria will be used:

5.1.1.1 Controlled Areas

A controlled area is a workplace in which an individual could be exposed to an annual

radiation dose greater than 6mSv. This annual dose is translated into the following criteria,

which are designed to ensure that the annual dose is not exceeded:

 The whole body dose rate exceeds 7.5 Sv/h averaged over 8 hours, or the dose rate to

the hands, forearms or feet exceeds 75 Sv/h.

(Note. Where the dose rate is less than 7.5

Sv/h, it will still be necessary to demonstrate by risk assessment that 6 mSv a year will

not be exceeded, otherwise a controlled area will be designated).

Controlled areas will also be designated in the following situations:

 For work involving mobile radioactive sources e.g. well logging, radiography and

radiotracer studies (Note. Work with mobile radioactive sources may give rise to dose

rates exceeding 7.5 Sv/h outside of the controlled area, provided that the exposure is of

short duration i.e. a few tens of seconds).

 Where a source of radiation has the potential to give rise to significant exposures over a

short period of time (e.g. X-ray equipment).

 Where work involving unsealed radioactive substances is carried out and there is a risk of

contamination being spread (including by airborne means) outside of the work area and if

there is potential for elevated exposures.

 Where a person is required to bodily enter an area in which contamination is, or may be,

present.

Requirements for Controlled Areas:

 The extent of any Controlled Area will be delineated by physical means;

 Where practicable, barriers will be erected to restrict access;

 Access shall be further restricted using the Safe Systems of Work;

 Radiation warning signs will be posted at all entrance points.

 Work in Controlled Areas shall only be carried out in accordance with applicable national

and international legislation.

Control Tier:

2-AzSPU

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 A Radiation Protection Supervisor shall be present at the commencement of all work

carried out in a Controlled Area. Once work has commenced, the RPS will carry out

periodic checks based on risk assessment of the task in hand.

NB: It should be remembered that decks above and below the source may require

barriers dependent on the dose rate.

An RPS may designate a temporary controlled area, without the need for barriers or warning

signs, on the basis that the duration of any work will be short (subject to risk assessment) and

access to the area can be adequately restricted.

Contractors who designate their own Controlled Areas shall do so using the criteria above.

Alternative arrangements that provide at least the same level of protection may be used.

In the event that a Contractor takes control of a Controlled Area established by the AzSPU

RPS, then the Controlled Area Handover Certificate (Appendix C) must be completed and

copies filed in the Site Radiation Records.

5.1.1.2 Supervised Areas

A supervised area will be designated in any area not already designated as a controlled area

but where occupational exposure conditions need to be kept under review, even though

specific protection measures and safety provisions are not normally needed.

A supervised area will be designated in any area where it is likely that someone could exceed

an effective dose of more than 1 mSv per year. This annual dose is translated into the

following criteria, which are designed to ensure that the annual dose is not exceeded:

 The whole body dose rate exceeds 1 Sv/h but is less than 7.5 Sv/h.

Based on the above, a supervised area will be designated as follows:

 Where routine radiation monitoring (including contamination monitoring) is carried out

for the purposes of keeping the conditions in that area under review.

 Where work with unsealed radioactive material is carried out for which a Controlled Area

has not already been designated and where there is little or no risk of a spread of

contamination i.e. the material can be easily contained.

Note. It will not automatically be necessary to set up a supervised area around every

controlled area, as the requirements for the controlled area are likely to be sufficient.

Requirements for Supervised Areas:

 Access to supervised areas designated on the basis of external dose rate will not normally

be restricted.

 Warning signs do not need to be displayed at all supervised areas, but they will be

displayed in the case of work with unsealed materials.

5.1.2 Radiation Procedures and Radiation Protection Supervisors

5.1.2.1 Radiation Procedures and Site-Specific Instructions

Control Tier:

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Radiation procedures are provided for all aspects of work with ionising radiation carried out

by AzSPU, including the management of contractors working with sources of ionising

radiation (see Section 6). The procedures contain, where appropriate, the following:

 Key working instructions for ensuring that radiation exposures are kept ALARP.

 Arrangements for monitoring exposures (area monitoring, personal monitoring, or a

combination of both).

 Dose investigation or trigger levels.

 Contingency plans for reasonably foreseeable incidents and accidents.

Additionally, site-specific instructions will be drawn up for any site that designates controlled

areas or Radioactive Substances Storage Areas, including those used for Contractor‟s sources.

The site-specific instructions will detail the local arrangements for radiation protection and

they must reflect the AzSPU Ionising Radiation Policy, the Radiation Protection Programme

and this procedure.

Contractors who designate their own controlled areas will be required to provide their own

procedures or site-specific instructions and Radiation Protection Officers.

5.1.2.2 Radiation Protection Supervisors (RPSs)

RPSs will be formally appointed by the Site Manager / OIM for the purpose of ensuring

compliance with the radiation procedures or site-specific instructions. Prior to appointment,

RPSs will attend a suitable training course, appropriate to the nature of the work and attain a

pass mark of at least 70%. A copy of the letter of appointment and the RPS‟s training

certificate will be maintained on site in the Site Radiation Record along with a Register of

Appointed RPSs.

Also, only those individuals who have the authority to exercise supervision over work with

ionising radiation will be appointed.

A copy of the Register of RPSs will be made available to the Control Room and Emergency

Response Team (ERT). The AzSPU Radiation Protection SPA should be notified in the event

that the Register of RPSs is amended.

As part of the annual audit, the RPA will review the competence of the RPSs and report his

findings to the Site Manger / OIM and the AzSPU Safety & Compliance Manager.

5.1.3 Monitoring of Workers, the Workplace, and Radiation Monitoring Equipment

5.1.3.1 Monitoring of Workers

In general, for any worker who is normally employed in a controlled area, or who

occasionally works in a controlled area and is likely to receive an annual exposure exceeding

6 mSv, individual dose assessment will be undertaken. Individual dose meters will be

provided in this instance. In consultation with the RPA, it may be possible in some

circumstances to assess occupational exposure on the basis of the results of monitoring of the

workplace and on information on the locations and durations of exposure of the worker. In

any case the RPA must be consulted if a risk assessment shows that individual dose

assessment may be necessary.

For any worker who is regularly employed in a supervised area or who enters a controlled

area only occasionally, individual monitoring will generally not be required, but the

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occupational exposure of the worker shall be assessed on the basis of the results of monitoring

of the workplace.

In both of the above cases, the exposure will be recorded on the Record of Entry Into

Controlled Areas (Appendix D) and the Radiation Exposure Log (Appendix E).

Dose assessment will not be required for workers who only enter supervised areas

occasionally, on the basis that occupancy rates will be low and the radiation levels are

routinely monitored.

In the unlikely event that work carried out by AzSPU will cause individual dose assessment to

be necessary (based on the outcome of a risk assessment), the RPS will be responsible for

issuing and collecting dose meters from the appropriate personnel. The RPS will be

responsible for examining the dose records to ensure that dose investigation levels are not

being exceeded.

It will be the responsibility of each worker issued with a dose meter to look after it and to

wear it when there is a potential for exposure. The dose meters will only be worn at work.

The wear period for dose meters will be determined by a risk assessment and with reference

to Decree No. 134 of the Cabinet of Ministers of AR “On Approval of the Rules on Form and

Completion of Radiological-Hygienic Passports of Territories, Enterprises and Organizations

and the Rules of Recordation and Control Over Individual Ray Doses”, 25.08.1999.

5.1.3.2 Monitoring of the Workplace

Where monitoring of the workplace is required on-site documents will specify:

 The quantities to be measured;

 Where and when the measurements are to be made and at what frequency;

 The most appropriate measurement methods and procedures;

 Reference levels and actions to be taken if they are exceeded;

 Who will perform the monitoring.

All monitoring will be carried out in accordance with the principles stated in Appendix F

(Radiation Monitoring).

5.1.3.3 Radiation Monitoring Equipment

AzSPU Operational Assets or Projects will provide suitable and sufficient monitoring

equipment, according to the nature of the work, where a requirement to carry out monitoring

has been identified in either procedures or risk assessments. This will include dose rate

meters, contamination monitors and where appropriate, personal air samplers. The RPA will

be consulted with regards to the suitability of any new radiation monitoring equipment being

used or purchased.

Radiation monitoring equipment will be calibrated at least once every twelve months by an

approved testing service; advice will be obtained by from the RPA if necessary. Additional

function tests shall be specified in the radiation procedures or local rules as appropriate.

The Site RPSs will maintain a Site Register of Radiation Monitoring Equipment (Appendix

G) that will include details of all dose rate and contamination monitors. The following

information will be recorded:

Control Tier:

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 Manufacturer

 Model

 Serial No.

 Date last tested

 Reason for test (i.e. “Routine” or “Damaged”)

 Next test due

All radiation monitoring instruments must be kept in a good state of repair and be inspected

for damage prior to use. Damaged instruments must not be used and will be sent for repair as

soon as is practicable.

Each site that uses contamination monitors will keep a test source so that the function of the

instrument can be checked prior to use. Details of the test source will be recorded in the Site

5.1.4 Recording and Reporting Monitoring Information

5.1.4.1 Occupational Radiation Protection and Safety (Risk Assessment)

The decisions regarding measures for occupational radiation protection and safety will be

determined by radiation risk assessments. The scope and content of the risk assessments will

be defined by the RPA. All radiation risk assessments will be site specific and records of risk

assessments will be maintained in the Site Radiation Records. The Radiation Risk

Assessments will be copied to the AzSPU RP SPA and Permitting and Regulatory Affairs.

Task Risk Assessments will be carried out for specific tasks with ionising radiation not

already covered by a general risk assessment.

Work with ionising radiation will be subject to the Permit to Work System.

5.1.4.2 Workplace Monitoring Records

The results of workplace monitoring will be recorded in the appropriate form in the radiation

procedures or local rules. Copies of the records will be kept in the Site Radiation Records for

review, auditing and compliance purposes.

5.1.4.3 Individual Monitoring Records

Where an individual is subject to personal dosimetry, a „personal record card‟ will be created

and a record of the individual‟s dose will be kept in accordance with the requirements of

Resolution 134 of the Cabinet of Ministers of the Azerbaijan Republic. Records will be

maintained while that individual is employed by BP and for 50 years following termination of

employment. If the individual leaves employment with BP to work for another employer,

then a copy of the individual‟s summary dose record will be made available to the new

employer.

5.1.4.4 Dose Investigation and Trigger Levels

In order to manage exposures, a Trigger Level and a Dose Investigation Level are used.

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

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Since personnel are not routinely exposed to radiation and are not required to wear personal

dose meters, the assessment and management of personal exposures will be based on the

results of workplace monitoring.

The trigger level is the dose rate at or above which an informal investigation should be carried

out by the RPS to determine the cause of the elevated dose rate and what actions are

necessary to re-establish normal conditions.

A trigger level is set at 7.5µSv/h. If a dose rate of 7.5µSv/h or above is measured during

routine monitoring, or vessel entry, then the RPS should immediately investigate to determine

the cause and take action as necessary to restrict exposure.

The dose investigation level is the dose at which exposures are deemed no longer ALARP and

a formal investigation is initiated to determine the cause of the exposure and the actions

needed to ensure that continued exposure is ALARP.

If any individual receives a dose in excess of 60 µSv in 8 hours, this will be investigated and

the AzSPU RP SPA and the RPA will be informed.

5.1.5 Provision of Training to Persons Involved in Work with Ionising Radiation

Everyone involved in work with ionising radiation will receive radiation protection

information, instruction and training as appropriate. The level of training required will be

agreed by the AzSPU Safety & Compliance Manager and the AzSPU Radiation Protection

SPA and reviewed periodically. The AzSPU Safety & Compliance Team will conduct audits

of the training as part of the AzSPU integrated HSE internal audit programme.

Management will receive training in the basic principles of radiation protection and their main

responsibilities within the Radiation Protection Programme.

It is the Site Manager / OIM‟s responsibility to ensure that workers who may be exposed to

ionising radiation and individuals with assigned responsibilities receive the necessary

training.

In particular, the Site Manager / OIM will ensure that persons required to supervise work with

ionising radiation, which includes supervising contractors working with ionising radiation,

attend an approved Radiation Protection Supervisors Training Course.

The Site Manager / OIM will also ensure that individuals who may be exposed to radiation as

a result of work carried out in a controlled or supervised area attend a Radiation Awareness

Training Course appropriate to the hazard involved e.g. Radiation Awareness for Gauge

Users, or Radiation Awareness for Persons Working with Naturally Occurring Radioactive

Material.

Emergency Response Teams (ERT) will receive specific training highlighting the potential

hazards and the steps to be taken to minimise potential exposures to the individuals in the

team and others.

Training courses and materials should be agreed with and approved by the AzSPU RP SPA

and the AzSPU Safety & Compliance Manager respectively.

Potential radiation hazards will also be included in general Site HSE inductions.

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

Document No: AzSPU-HSSE-DOC-00058-2

Print Date: 2/1/2011

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5.1.6 Periodic Reviews / Audits of Performance and Compliance

The RPA will carry out radiation safety and compliance audits at all facilities and sites where

there is occupational exposure to ionising radiation. The RPA will report his findings to the

Site Manager / OIM, the AzSPU Safety & Compliance Manager and the AzSPU RP SPA.

Any significant findings will be discussed at the Quarterly Cross-SPU HSE meeting.

5.1.7 Provision of Contingency Plans to Address Incidents / Accidents

All reasonably foreseeable incidents and accidents will be identified in a radiation risk

assessment.

In case of any incident involving radioactive materials, the AzSPU Radiation Contingency

Plan (AzSPU-HSSE-DOC-00086-2) shall be followed. This document also describes the

process for notifying authorities in the event of an incident.

5.1.8 Provision of a Health Surveillance Programme

Specific health surveillance, over and above routine health surveillance, will not be carried

out, except in the case of workers for whom a risk assessment has shown that they are likely

to receive an effective dose in excess of 6 mSv in a year.

5.2

Management of Contractors Working With Ionising Radiation

The use of radioactive materials in either a sealed or unsealed form and the use of radiation

generating equipment such as X-ray machines, is carried out from time to time by Contractors

operating on AzSPU managed sites, both offshore and onshore.

The most common uses of ionising radiation include the following:

 Industrial radiography using sealed sources or X-ray machines.

 Well logging using gamma and neutron sealed sources (either wire-line operations or

measuring while drilling techniques) and Minitron neutron generators.

 Vessel, pipe or jacket member scanning using sealed sources.

 Radiotracer work involving the injection of unsealed radioactive material into a vessel or

pipeline.

In the special case of work involving Naturally Occurring Radioactive Material (NORM),

AzSPU is responsible for managing the HSE aspects on the basis that the material has arisen

as a direct result of AzSPU operations i.e. the extraction of oil and gas. This work is covered

by the Procedure for Working with Naturally Occurring Radioactive Materials (NORM)

(AzSPU-DOC-HSSE-00097-2).

Work with ionising radiation carried out by contractors has the potential to cause radiation

exposure of other persons working nearby. In the case of AzSPU managed sites, this includes

AzSPU personnel, other contractors, and visitors to the site.

5.2.1 Management Arrangements

Site Management have the ultimate responsibility for ensuring that work with ionising

radiation is carried out in accordance with this procedure and the Radiation Protection Plan.

This responsibility cannot be delegated to employees, workers, the radiation protection

supervisor (RPS), the AzSPU RP SPA, the RPA or anyone else.

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

Document No: AzSPU-HSSE-DOC-00058-2

Print Date: 2/1/2011

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All persons who may be affected by the content of this procedure should be made aware of

the relevant details. Site management will enable a free flow of radiation protection and

safety related matters between workers and management.

5.2.2 Responsibilities

Responsibility for ensuring that work with ionising radiation is carried out safely and in

accordance with the regulatory requirements generally rests with the owners and users of

sources of ionising radiation, whether radioactive materials or radiation generating equipment

such as X-ray machines.

Where radioactive materials need to be imported (or exported) for the intended work and

where the work may involve a change of ownership of radioactive sources from a third party

to AzSPU (e.g. where sources are installed in nucleonic equipment), then the Procedure for

Import / Export of Radioactive Materials and Sources of Ionising Radiation (AzSPU-HSSE-

DOC-00083-2) must be implemented. This is to ensure that contractors / subcontractors are

aware of the statutory requirements in the Azerbaijan legislation, and that the necessary forms

are completed and forwarded to the Permitting and Regulatory Affairs Team prior to a Permit

being issued by the authorities. This process also allows the Permitting and Regulatory

Affairs Advisor to maintain an up to date radioactive source inventory.

Contractors carrying out work with ionising radiation on AzSPU managed sites have a duty to

carry out that work so that they achieve a suitable level of protection of themselves and other

persons, including AzSPU personnel, other contractors, and site visitors who could be

affected by their work.

AzSPU has a duty to ensure so far as is practicable that only suitably trained and qualified

personnel, who have been deemed competent, undertake work with ionising radiation on any

AzSPU managed site. To this end, arrangements should be made at the contractual stage to

verify that the contractor meets a minimum level of competence and is aware of the AzSPU

requirements specified here. AzSPU however is not responsible for the competence of the

contractor and it is a legal obligation of the contractor to ensure that his staff have received

suitable training and are competent to conduct work with ionising radiation.

The method of controlling this type of work is based on a two-stage process, aimed at

verifying a minimum level of competence of the contractor. The first stage involves a review

of the contractor‟s arrangements for managing the proposed scope of work safely and in

accordance with the applicable legislation. Verification needs to be made at the contractual

stage so that contracts are not signed unless the Contractor has demonstrated a minimum level

of competence.

The second stage focuses on verifying the competence of the individual personnel who will

be carrying out the work and ensuring that they have appropriate resources to allow them to

carry out the work safely.

5.2.3 Contractor’s Arrangements for Managing Work with Ionising Radiation

Contractors must be able to demonstrate that they have effective systems in place for

managing work with ionising radiation.

PSCM will include a requirement for contractors to provide documentary evidence of their

radiation management system, which must be reviewed by the relevant Technical Authority

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

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or Subject Matter Expert (SME) in consultation with the AzSPU RP SPA and relevant RPS if

necessary, before a contract is awarded. Alignment with the AzSPU radiation procedures

should also be ensured. If necessary the RPA should be contacted for further assistance.

As a minimum, the contractor must have the following in place as part of their management

system:

5.2.3.1 Special Permit

A copy of the Special Permit to carry out work with ionising radiation for the type of work

included in the proposed scope of work. Special Permits are issued by the State Committee

for the Supervision of Safe Industrial and Mining Practices (SCSSIMP) of the Ministry of

Emergency Situations and are valid for three years. Details on permitting processes are

provided in the Radioactive Materials Regulatory Management System, The Import / Export

of Radioactive Materials and Sources of Ionising Radiation Procedure (AzSPU-HSSE-DOC-

00083-2).

Work with ionising radiation must not be carried out if a contractor does not have a Special

Permit. If the Special Permit is due to expire prior to the end of the proposed scope of work

then the contractor must provide evidence of the arrangements that have been made to obtain

a new licence at that time.

5.2.3.2 Radiological Hygiene Passport

In addition to the Special Permit, the contractor must have a current Radiological Hygiene

Passport that is approved by the Centre of Hygiene and Epidemiology of the Ministry of

Health and SCSSIMP of the Ministry of Emergency Situations. Radiological Hygiene

Passports are valid for a period of one year.

5.2.3.3 Risk Assessment

A suitable risk assessment, which may be in the form of a generic risk assessment for the

proposed scope of work, must be available. The risk assessment will identify the ordinary

control measures that are required to carry out the work safely. The risk assessment will also

identify all reasonably foreseeable accidents or incidents and the steps that are necessary to

prevent these accidents, or to mitigate their consequences. Job specific risk assessments may

be necessary prior to work commencing.

5.2.3.4 Radiation Procedures

A copy of the Contractor‟s „Radiation Procedures‟ (or „Site-Specific Instructions‟ etc), which

describe the arrangements for the management of the radiation protection aspects of the

intended scope of work are required. The procedures should describe any controlled or

supervised areas, how access to these areas will be restricted, and how radiation exposures

will be assessed. In particular, the procedures should describe how the radiation exposure of

personnel who are not employed by the contractor will be both controlled and assessed e.g. a

driller who is exposed in the doghouse when well logging sources are handled on the drill

floor.

The equipment used to restrict radiation exposure must be described in the procedures,

including any barriers, warning signs and warning devices, and PPE where appropriate.

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

Document No: AzSPU-HSSE-DOC-00058-2

Print Date: 2/1/2011

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5.2.3.5 Contractor’s Personnel & Training Records

A list of all personnel who may be involved in the work must be submitted to the Technical

Specialist (formerly CAM) along with evidence of relevant training and copies of training

certificates, prior to arrival of the contractor at the site / facility. The Technical Specialist will

forward these records on to the site RPS and Site Manager / OIM.

Training records must demonstrate that personnel who are responsible for putting the

emergency response plan into effect have received appropriate training.

In the event that the contractor wishes to include additional personnel to the work team after

the work has commenced, he must submit the same information to the Technical Specialist

and the site RPS and Site Manager / OIM.

5.2.3.6 Radiation Monitoring Equipment

The contractor should specify what radiation monitoring equipment will be used for the work.

The monitoring equipment must be suitable for the type of work and calibration / test

certificates must be supplied that show that the equipment has been tested (and passed the

test) within the last twelve months. It must be clearly stated in any contract that the

contractor is responsible for providing such equipment.

5.2.3.7 Radioactive Materials and Radiation Generating Equipment

Details of all radioactive materials and radiation generating equipment to be used for the

scope of work must be supplied. For radioactive materials this will include the following:

 Radionuclide e.g. caesium-137, krypton-85.

 Form of the material e.g. gas, liquid, sealed source or Special Form source (note, in the

case of a Special Form source a copy of the Special Form Certificate for the source must

be supplied).

 Activity of the radioactive material with a reference date.

 Details of the equipment that the radioactive materials will be used in and evidence that

this meets applicable international standards.

 Evidence that the equipment is subject to a routine maintenance and inspection

programme.

For radiation generators, the following details must be supplied:

 Type of equipment e.g. X-ray equipment or neutron generator.

 Nature of radiation produced i.e. energy of the radiation.

 Evidence that the equipment meets applicable international standards.

 Evidence that the equipment is subject to a routine maintenance and inspection

programme.

5.2.3.8 Emergency Preparedness

The contractor must have a documented emergency response plan (also known as a radiation

contingency plan). The emergency response plan must include:

 A list of potential incidents and accidents.

 Procedures to be followed in the event of an incident or accident.

Control Tier:

2-AzSPU

Revision Date: October 04, 2010

Document No: AzSPU-HSSE-DOC-00058-2

Print Date: 2/1/2011

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Military reference books and manuals (2009-2023, Volume 4) - page 30