radiography equipment inspection and maintenance(2) inspection and maintenance necessary to maintain...

RADIOGRAPHY EQUIPMENT INSPECTION and MAINTENANCE

Law of Nature:

It is statically inevitable that a poor inspection and maintenance program will eventually result in equipment

malfunctions & serious acute overexposure incidents.

ACCIDENTAHEAD

What is the difference between Maintenance and Repairs?

Are radiography companies required to perform Routine Maintenance?

Sec. 34.31 Inspection & maintenance of radiographic exposure devices, transport & storage containers, associated equipment, source changers, & survey instruments

10 CFR Part 34 Requirements

Sec. 34.31 Inspection and maintenance of radiographic exposure devices, transport and storage containers, associated equipment, source changers, and survey instruments.

(a) The licensee shall perform visual and operability checks on survey meters, radiographic exposure devices, transport and storage containers, associated equipment and source changers before use on each day the equipment is to be used to ensure that the equipment is in good working condition, that the sources are adequately shielded, and that required labeling is present. Survey instrument operability must be performed using check sources or other appropriate means. If equipment problems are found, the equipment must be removed from service until repaired.

(b) E h li h ll h itt d f(b) Each licensee shall have written procedures for:(1) Inspection and routine maintenance of radiographic exposure devices, source changers, associated equipment, transport and storage containers, and survey instruments at intervals not to exceed 3 months or before the first use thereafter to ensure the proper functioning of components important to safety. Replacement components shall meet design specifications. If equipment problems are found, the equipment must be removed from service until repaired.(2) Inspection and maintenance necessary to maintain the Type B packaging used to transport radioactive materials. The inspection and maintenance program must include procedures to assure that Type B packages are shipped and maintained in accordance with the certificate of compliance or other approval.(3) Records of equipment problems and of any maintenance performed under paragraphs (a) and (b) of this section must be made in accordance with Sec. 34.73.

10 CFR Part 34 Requirements

Sec. 34.73 Records of inspection & maintenance of radiographic exposure devices, transport & storage containers, associated equipment, source changers, & survey instruments

Sec. 34.73 Records of inspection and maintenance of radiographic exposure devices, transport and storage containers, associated equipment, source changers, and survey instruments.

(a) Each licensee shall maintain records specified in Sec. 34.31 of equipment problems found in daily checks and quarterly inspections of radiographic exposure devices, transport and storage containers, associated equipment, source changers, and survey instruments; and retain each record for 3 years after it issurvey instruments; and retain each record for 3 years after it is made.

(b) The record must include the date of check or inspection, name of inspector, equipment involved, any problems found, and what repair and/or maintenance, if any, was done.

What is Routine Maintenance?

What is Routine Maintenance?

Maintenance that is performed i hi ifi d i i dwithin a specified time period.

What is Preventive Maintenance?

What is Preventive Maintenance?

Maintenance that is performed to i lf iprevent equipment malfunctions.

Is there a difference between Routine Maintenance and Preventive Maintenance?

Is there a difference between Routine Maintenance and Preventive Maintenance?

R i M i i b d iRoutine Maint is based on timePreventive Maint is based on need

Program-Specific Guidance About Industrial Radiography Licenses - Final Report (NUREG-1556, Vol. 2)

8.10.8 Quarterly Maintenance

Criteria: The licensee shall have written procedures for inspecting and maintaining radiographic exposure devices, source changers, associated equipment, transport and storage containers, and survey instruments.

Discussion: These procedures are intended to allow the licensee's staff to evaluate equipment used in radiography for safe continued use, to provide a record of this evaluation, and to guide the staff in maintenance. These procedures may be based on the manufacturer's recommendations.

U.S. NRC Role

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICESSAFETY EVALUATION OF DEVICEDEVICE TYPE: Radiographic Exposure device

MODEL: SPEC 150

Reviewer Notes/License conditions:

1. The only parts of the SPEC 150 which are allowed to be removed by the licensee are the ASM/lock module and the outlet panel assembly. Source Production and Equipment Company does not authorize any repair to these components by licensees. The components may only be replaced (not repaired) by the licensee. The licensee must provide clear protocol for anyone who performs replacement and other maintenance, and at what intervals.

SPEC-150 Maintenance & Repair Procedures

8.1 General

Although daily & quarterly safety inspections are required by regulations, there are no daily or quarterly maintenance requirements for the SPEC-150 exposure device to comply with the warranty conditions for thedevice to comply with the warranty conditions for the product.

Maintenance & repairs of the SPEC-150 & associated equipment must be done on an as-needed basis in response to safety inspections & malfunction reports from the workers.

Safety Evaluation of DeviceDevice Type: Radiographic Exposure device

Mfr.: QSA Global Model: 660

5.8 Maintenance Requirements

E i h ld b l l i d f i h

Registry of Sealed Sources & Devices

Equipment should be completely serviced after it has been subjected to severe conditions (e.g., immersed in water or mud, in a sand storm, dropped, etc) per Section 5.10.

5.10 Complete Service

Equipment which is used under good condition shouldonly require complete service annually.

Safety Evaluation of DeviceDevice Type: Radiographic Exposure device

Mfr.: INC Model: IR-100

Maintenance

General

Registry of Sealed Sources & Devices

General

It is imperative that all components be kept clean.No amount of dirt can be regarded as negligible.

In reality, are radiography companies required to perform true Routine Maintenance?

NO!

In reality, they are required to perform routine inspections…. and to repairdefective equipment, as needed.

Are radiography companies required to develop Routine Maintenance written procedures?

Yes.

How frequently should preventivemaintenance be conducted?

Yes.

How frequently should preventivemaintenance be conducted?

Th f h ld b b d hThe frequency should be based on the performance history of the specific equipment and the environmental conditions of use.

Regulations require Daily and Quarterly equipment inspections. Which is more effective at preventing equipment malfunctions?

Regulations require Daily and Quarterly equipment inspections. Which is more effective at preventing equipment malfunctions?

A D il I iAnswer: Daily Inspections

NMED Malfunction Reports

TYPE of MALFUNCTION TOTAL

Drive Cable/Source Disconnect 43

Other/Miscellaneous/Unknown 39

Guide Tube Damage 29g

Camera ASM Malfunction, Premature tripping 28

Camera & Source Misconnect 13

Control Ass'y Damage/Malfunction 13

Camera Lock Malfunction 6

WIPE TEST PROCEDURE FOR DEPLETED URANIUM (DU) SHIELDS

Use a swab to wipe the interior surface of the S-Tube. Wipe the entire length of the S-Tube (or to the source assembly if the exposure device is loaded). Test the first swab for DU contamination. If the wipe test indicates DU contamination an inspection (e g visualDU contamination, an inspection (e.g., visual inspection, eddy current, etc.) must be performed of the S-tube interior. If the inspection indicates that the S-Tube is worn through to the DU shield the device shall be removed from service.

Recent Failures of Control Cables Used On Amersham Model 660 Posilock

U.S. NRC Information Notice 97-91

Amersham Model 660 Posilock Radiography Systems

Available at: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1997/in97091s1.html/

U.S. NRC NUREG-1631

U.S. NRC NUREG-1631

EXECUTIVE SUMMARY

The cable is not designed for use in industrial radiography.It is designed for use in the aerospace, marine, and other industries as a component in cable control systems. These systems are specifically designed for their intended operating environment and use conditions, which are markedly different then those of the industrial radiography industry.

The importance of radiography drive cables is not sufficientlyThe importance of radiography drive cables is not sufficiently emphasized.

Manufacturers, the radiography industry and regulatory agencies have not adequately emphasized the importance of observing and evaluating the condition of radiography drive cables. As a result, opportunities to detect precursor events may have been missed due to incomplete or ineffective visual examination and/or maintenance.

Radiography Control Assembly Drive Cable Inspection, Cleaning & Lubrication

This information is provided for guidance regarding the inspection and maintenance of drive cables. Radiography companies should combine this information with their own

NDTMA Bulletin – Feb. 2000

companies should combine this information with their own knowledge and experience to develop procedures that are best for them based on the environmental conditions of use.

Drive cable connector inspection & maintenance is not included due to the disparity in connector designs & inspection procedures. The connector manufacturers should be contacted to obtain inspection procedures.



Inspection

A. Visually check for defects such as rust, broken strands, kinks, excessive wear, & excessive space between strands., p

B. Physically inspect for stiffness by bending the last 6 inches of the cable into a "U" shape approximately 3 inches wide. When the end of the cable is released the cable should spring back to an essentially straight shape. Failure to spring back indicates that corrosion or other abnormality has reduced the flexibility of the cable.



Cleaning

Frequency: 3 months & as needed based on daily inspections

S l t A l t h hth i l i it

Diesel - do not add dry graphite lubricationWD-40 - allow to dry before applying other lubricationsWater based solvents - dry thoroughly & immediately

Solvents: Any grease solvent such as naphtha, mineral spirits, varsol, gasoline, or acetone

These solvents may be used under special conditions:

Not recommended: water


Lubrication

Dry/Hot Environments:Graphite; Neolube by Huron IndustriesSilicone Grease - very light coat, Dow Corning DC33

(temp range: -100oF to +355oF) Mil-G-23827B (temp range: -94oF to +248oF)Moly Dry FilmMoly Dry FilmNot recommended: Heavy oils or thick coat of grease

Wet Environments:Silicone Grease, Dow Corning DC33Mil-G-23827B, DieselNot recommended: Dry graphite

Sub-Freezing Environments:Very dry cable - no lubricationSilicone Grease; Dow Corning DC33, G.E Verselube Mil-G-23827B, Moly Dry FilmNot recommended: Anything that thickens or freezes


Notes

1. A lubrication that is suitable for one environmentmight not be suitable for other environments.

2. Lubrication should be applied immediately aftercleaning to prevent oxidation.cleaning to prevent oxidation.

3. Use of Houghto-quench G oil after cleaning isrecommended by the mfr. of drive cable

material;however, this is not a common practice in theradiography industry.

IP 87121 (Industrial Radiography Programs) has been revised to reflect that the previous practice of registering associated equipment under 10 CFR 32.210 was not required and the NRC has discontinued that practice.

NRC INSPECTION MANUAL INSPECTION PROCEDURE 87121 (excerpts)INDUSTRIAL RADIOGRAPHY PROGRAMS

b. Routine and Non-Routine Maintenance.

Through direct examination, assess the condition of licensee equipment,i.e. cameras, drive cables, source changers, etc. The examination shouldbe sufficiently thorough to detect any of the following conditions:excessive or uneven wearing, fraying, unraveling, nicks, kinks or bends,g y g gloss of flexibility (abnormal stiffness), excessive grit or dirt, andstretching.

1. Should a defect, such as a damaged cable, be found in use, notify anappropriate licensee representative and then expand the scope of theexamination. Monitor actions, if any, taken by the licensee inresponse to this discovery. Should the licensee elect to not takeaction, the inspector should consult with regional management.

2. Verify that the licensee has an inspection and maintenance programthat complies with 10 CFR 34.31(a) and provides for visual andoperability checks of radiographic equipment, survey meters, transportcontainers, associated equipment, and source changers before useco ta e s, assoc ated equ p e t, a d sou ce c a ge s be o e useand quarterly to ensure that the equipment is in good workingcondition.

3. The inspector should verify that the licensee is aware of the requirementscontained in 10 CFR Part 21 and 10 CFR 34.101(a), and has procedures inplace for reporting defects and certain equipment failures.

What can RSO’s do to reduce equipment malfunctions?


• Develop a true preventive maintenance program based on specific equipment performance history and environmental conditions of use.



• Provide inspection training and actively enforce the dailyinspection requirement.



• Provide inspection training and actively enforce the dailyinspection requirement.

• Request that the NRC grant access (again) to the Nuclear Material Events Database (NMED) to evaluate equipment performance histories.

Quarterly Equipment Inspection & Maintenance

Questions?

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