Integration of Occupational Safety and Radiation

Protection during Decommissioning and Disposal

(D&D) Works (OP8-3)


Noraishah binti PUNGUT
1
, Siti Afidah binti AWANG
1
, Hiromichi SAKAI, Ph.D.
2
, Robert J.
BRUCE
3
, Daniel T. DUFFY
3
, Anthony GOH
3
, Razali bin HARUN
3
, Syaiful Iskandar bin YAHAYA3,
and Syed Abdul Malik bin SYED ZAIN, Ph.D.
4

1
Atomic Energy Licensing Board, Ministry of Science, Technology and Innovation, Malaysia;
2
Asian Rare Earth Sdn.
Bhd., Ipoh, Malaysia;
3
Geosyntec Consultants Sdn. Bhd., Kuala Lumpur, Malaysia;
4
Independent Radiation Protection
Advisor, Bangi, Malaysia
Introduction
This presentation provides some of the safety aspects during
the Decommissioning and Disposal (D&D) of Long Term
Storage Facility in Mukim Belanja, Perak, Malaysia
With a great support from subcontractors, project personnel,
vendors, suppliers, regulatory agencies, and others, the
project has achieved a significant safety record without any
major incident or accident
Background
Decommissioning and Disposal (D&D) of the Long Term
Storage Facility (LTSF) project in Perak, Malaysia.
The LTSF-D&D project commenced in early 2010 and expected
to complete by end 2014
LTSF
The LTSF contained over 87,000 drums of low level Naturally
Occurring Radioactive Materials (NORM) waste residues that
were generated from the processing of monazite and
xenotime ores
Main Activity
The LTSF-D&D project involved:
the removal and processing of the LTSF contents,
demolition of the LTSF structure, and
dispose of these materials into a disposal facility,
Engineered Cell 2 (EC 2).
Early Stage
During 2010 and the first half of 2011, work at the Site
consisted of general construction activities included;
earthworks,
building construction,
electrical construction, and
installation of plant and equipment.
Actual D&D Work
The actual D&D work was
commenced in the middle of 2011
and was completed end of 2013

Involved drums retrieval, processing
and waste placement activities

Semi-automated mechanical and
robotic equipment were employed
to ease the D&D activity
Workforce
The workforce in Malaysia is multi-ethnic and the first major
challenge on the project was to manage communication to
workers originating from multi-national backgrounds
including;
the United States,
the United Kingdom,
Australia,
Indonesia,
India,
Bangladesh,
Pakistan, and
Nepal
Strategy
Developed a safety culture on the
project
Promoted a behavior-based safety
program
Sharing safety and health information
Management support necessary to
make safe decisions
Training program
Safety promotion such as quizzes and
best safety award
Established Work Permit system
Enforcement Agency
Conventional construction safety under the jurisdiction of the
Malaysian Department of Occupational Safety and Health
(DOSH); and

Radiation protection under the jurisdiction of the Malaysian
Atomic Energy Licensing Board (AELB).
Regulatory Requirements
The project was designed to integrate the requirements of
occupational safety and health, and radiation protection to
comply with the Malaysian regulatory requirements

Atomic Energy Licensing Act 1984 [Act 304]
Occupational Safety and Health Act 1994 [Act 514]
Factories and Machinery Act 1967 [Act 139]
Construction Industry Development Board Act 1994 [Act
520]
Collaboration with Agency
Review of Safety Plan and Radiation Protection Plan
Safety training, site briefing and regular safety updates
Site inspection and monitoring
Emergency drill exercise
Monitoring
Plant and equipment inspected and
endorsed by DOSH

Monitoring and supervision by AELB

Regular safety site walk by project
safety and health, and radiation
protection personnel
Safety Committee
A Project Occupational Health and Safety Committee (POSHC)
was established
Met every month chaired by Project Manager
Member of POSCH consisted:
Safety and Health Officer (Secretary)
Radiation Protection Officer (RPO)
Management Representatives
Worker Representatives
Supervisors
Radiation Protection Action Group (RPAG) was another
committee that was established to manage radiation issues
chaired by the RPO

Safety Committee (continue)
POSHC and RPAG discussed issues
associated with occupational safety
and radiation protection included:
safety performance and
statistics,
monitoring data and dose
reporting,
training program,
housekeeping and personal
hygiene,
ALARA observation and
safety promotion and campaign.
Registration
The construction site and the
installed plant were registered with
DOSH under OSHA 1994 and FMA
1967

All workers were trained and
registered as a Construction Worker
under CIDB Act 520

Workers handling radioactive waste
materials were trained and
registered as a Radiation Worker
under Act 304
Training
The objective was workers would have a base level of
understanding and appreciation of the hazards,
considerations, requirements, and expectations associated
with the work
A Basic Radiation Safety Training was conducted in a
collaboration with AELB
Training (Continue)
Training
Program
Non- Radiation Radiation
Workers Supervisor Workers Technician Supervisor
Construction Safety (CIDB)

Site Induction
Work Permits and Job
Hazard Analysis

Quality Control and
Quality Assurance

Emergency Response
First Aid
Radiation Awareness
Basic Radiation Safety
Training (BRST)

Radiation Work Permits
Radiation Safety for
Technicians

Radiation Safety for
Supervisors

Contamination Control,
Survey and Monitoring

Institutional Safety Controls
Task Plan (TP)
Standard Operating Procedures (SOPs)
Risk Assessment Worksheet (RAW)
Job Hazards Analysis (JHA)
Radiation Work Permit (RWP)
Permit to Work (PTW) Daily requirement
Procedures
Work procedures and standard
operating procedures (SOPs) were
developed and implemented

Supervisors and workers were
trained using the relevant
procedure and to be aware of
identified hazards
Work Permits
Work permits were implemented
during project

Permit to Work
Radiation Work Permit
Lifting Permit
Hot Work Permit
Excavation Permit
Lock Out Tag Out (LOTO)
Job Hazards Analysis
Adopted from U.S. Department of Labor, Occupational Safety
and Health Administration Job Hazard Analysis, OSHA 30714
To identify
potential
hazards
To analyze the
risks
To evaluate
procedural
problems
To provide
safety
requirements
Worker
briefing
Radiation Work Permit
An administrative tool used to control work occurring inside
the radiation work zones
Specify known
radioactivity
levels in work
place
If supplemental
dosimeter
required
What minimum
PPE is needed
What
monitoring
required
Workers aware
of specific
hazards
Radiation Work Zones
Personal Protective Equipment
PPE provided to all workers on
project
Critical for protection from
radioactive contamination
Workers were trained for the correct
use and maintain of their PPE
Respiratory protection implemented
Safety Achievement
The project achieved over 3 million man-hours without a lost-
time-injury (LTI)
Safety Achievement
The same team on the Plant D&D and LTSF-D&D projects
achieved over 4.5 million man-hours without an LTI
Safety Achievement
The Project was successfully completed without any significant
radiation exposure to workers (the dose results below the
regulatory limit of 20 mSv/year)
252
38 37
13
4
0 0 0 0 0 0 0 0 0
238
48
25
16
11
5 6
13 13
5 7 5 3
0
174
41
13
10
17 19
14
26
7 8
4
0 0 0
0
50
100
150
200
250
300
N
o
.

o
f

R
a
d
i
a
t
i
o
n

W
o
r
k
e
r
s
Cumulative Dose(mSv/year)
2011 2012 2013
Safety is our priority

Thank You