1. REGULATORY INFRASTRUCTURE IN TURKIYE (Industrial Radiography)
Sinan ÖZGÜR
TURKISH ATOMIC ENERGY AUTHORITY
RADIATION HEALTH AND SAFETY DEPARTMENT
RADIATION SAFETY INSPECTION DIVISION

2. Legislation Framework Authorization - Licenseing Training Inspection
OUTLINE
Responsibilities and Functions of the Regulatory Body
Legislation Framework
Authorization - Licenseing
Training
Inspection
Enforcement

3. Regulatory Body - TAEA
Turkish Atomic Energy Authority (TAEA) is responsible regulatory body for radiation and nuclear safety and security.
Main Departments responsible for regulation are:
Nuclear Safety Department (NSD)
Radiation Health and Safety Deaprtment (RHSD)
Research and Training Centers are:
Ankara Nucelar Research and Training Center ( mainly is responsible for training of radiation protection officers (RPO) and radiation workers )
Cekmece Nuclear Research and Training Center (wich is in Istanbul)
Saraykoy Nucelar Research and Training Center

4. Radiation Health and Safety Department
Radiation Safety Inspection Division
Safety of Radiation Applications Division
Radioactive Source Management Division
Radiation Protection Division

5. The Regulatory Body
Turkish Atomic Energy Authority is the governmental organization empowered, by the Turkish Atomic Energy Act No. 2690, of 13 July 1982.
TAEA Act
reaffirms Türkiye’s attachment to the peaceful use of atomic energy,
authorizes TAEA to carry out the activities related with the fulfillment of Türkiye’s obligations arising from international agreements,
covers the establishment, management, duties, responsibilities and the authorizations of the TAEA.

6. The Regulatory Body TAEA is responsible
to determine the bases of the national policy for the peaceful use of atomic energy for the benefit of the country
to determine the principles, the measures and the limits of liability for radiation protection
to authorize organizations or persons who keep, use, import, export, transport, store and trade radioactive materials and radiation equipments and to inspect them
to take the necessary measures, or have them taken, for processing, transportation and permanent or temporary storage of radioactive wastes safely
to prepare necessary decrees, regulations technical and guides for those purposes
to train the personnel who will work in the nuclear and radiaton field or to assist their training if necessary

7. Legislation Framework
Turkish Atomic Energy Authority Act
Radiation Safety Decree
Regulation on Radiation Safety
Regulation on Licensing and Radiation Protection in Industrial Radiography
Regulation on the Safe Transport of Radioactive Materials
Regulation on the Control of High Activity Sealed Radioactive Sources
and Orphan Sources
Regulation on Radiation Safety Inspections and Enforcements
Regulation on Nuclear and Radiological Emergency

8. Legislation Framework
Regulation on The Protection of Outside Workers Exposed to Ionizing Radiation
Regulation on Wastes Arising from Use of Radioactive Substances
Regulation on the Licensing and Safety of Gamma and Electron Beam Irradiation Facilities
Regulation on Licensing of the Facilities Including Ionizing Radiation Sources for Therapy Purposes in Medicine
Regulation on Radioactive Waste Management

9. Authorization
Authorization is based on both TAEA Act No. 2690, Regulation on Radiation Safety and Regulation on Licensing and Radiation Protection in Industrial Radiography.
By Regulation on Radiation Safety;
It is obligatory to get license from the TAEA for: to keep, use, produce, import, export, purchase, sell, transport, store, maintain, repair, install, dismantle and exchange of of the ionazing radiation sources.
licenses are valid for 5 years
Persons or organizations having license for import, export and transfer of the radioactive sources also are obliged to get permission from TAEA for each import, export and transfer.
Import-Export Permissions for radioactive sources are valid for
3 months

10. Licenseing Process APPLICATION REWIEV OF DOCUMENTS BY TAEA-RHSD
IMPORT PERMISSION
PUNCH LIST – OFFICIAL LETTER IS SENT
PRE-INSPECTTION
LICENSE
SECOND REWIEV OF DOCUMENTS BY TAEA-RHSD

11. Authorization Numbers:
Industrial Raidography devices in total (including X-ray and gamma graphy)
Mobile gamma graphy devices (with radioactive sources)
328 X-Ray Devices (radiography – radioscopy)
X-ray radioscopy with cabin
X-Ray crawler devices
300 X-ray devices (all types)
Authorization by Licence: for use and transport of gamma graphy devices
To get license from TAEA, the company is obliged to provide following:
Application form that includes all official info about the licensee and radiation protection officer (RPO), official info about company, technical specifications and information about device and source, written egagement and etc..
RPO official documents : NDT certificate, Certificates of Trainings in radiation protection, health certificate and etc..
Radiographers(workers) documents: NDT certificate, Certificates of Trainings in radiation protection, health certificate and etc.
Emergency Plan,
GPS information: When and from WHO was bought, how it works and etc..
Type B(U) Certificate (it has to be valid internattionaly)

12. Authorization
Authorization by Licence: for maintanence and change of source in gamma graphy devices
There are 3 establishments and 1 government institution (CNAEM) which have license for maintenance and changing radioactive sources in gamma graphy devices in Türkiye.
Transportation of gamma graphy devices
Industrial radiography companies which have license for radiography devices, can do transportation with compatible vehicles only for their own devices.
There are also many companies that have license for transport of radioactive material and sources. They also may do transportation of these devices but this is not common. Generally industrial radiography companies which have license do that by their own.

13. Import Permission
Authorized importer provides the following information to TAEA :
name of the authorized recipient,
recipient’s legal address,
type of radionuclide, its activity, date of activity,
identifier informations about the source,
use of the source
repatriation agreement with the producer
The import permission for a radioactive source is given only in two cases:
If the radioactive source is being imported to user which have the license from TAEA. (licensee)
If the end user apply for license and licensee is approved from TAEA

14. Regulation on Licensing and Radiation Protection in Industrial Radiography
PART I
Purpose:
To ensure radiation protection of people, workers and environment against ionizing radiation during the applications in industrial radiography and to ensure the security of radioactive sources used in industrial radiography.
Scope:
This regulation includes the principles in order to ensure the radiation safety system and radiation protection, principles for licensing procedures and principles to ensure security of radioactive sources in industrial radiography applications.
Definitions
Exemptions

15. Regulation on Licensing and Radiation Protection in Industrial Radiography
PART II - License, Permissions, Responsibility and Exigencies.
PART III - Basic Safety Satndarts, Working Areas and Training of Radiaographers (workers) and certification.
PART IV – Management of Radioactive sources (maintenance of devices and renewal of radioactive sources, end of life procedures and waste management)
PART V – Transport and storage of radiography devices
PART VI – Categorization, Technical Specifications for Radiaography Devices, Working Methods, Radiation Protection.
PART VII – Emergency Situations, Records and Inspection.
PART VIII – Administrative and Other Provisions.

16. Technical Guide - RSGD-TD-ER-1
RSGD-TD-ER-1 (Technical Guide)
Attachment of Regulation on Licensing and Radiation Protection in Industrial Radiography
RSGD-TD-ER-1 Contents :
Defines contents and methodology of training for radiographers and certification method.
Certificate of the successful radiographers is valid for five years and every five years it has to be renewed.
Defines working areas and methodology, giving many practical procedures during work, practical dose ratio limits ito be used
Gives an example of practical emergency plan for gamma graphy and defines responsibilities in this plan giving an idea how it should be.
Includes some useful data and information like a units of activity, types of dose and etc. Also it gives some useful data about sources mostly used in gamma graphy such a decay table and etc.
Defines procedures and basic safety standarts during the transport of devices.
Gives information about labelling during the transport.

17. Inspection in Industrial Radiography
There are three main regulations used for inspection and enforcement in industrial radiography:
Regulation on Radiation Safety Inspections and Enforcements
Directive on Radiation Safety Inspections and Enforcement
Regulation on Radiation Safety
Regulation on Licensing and Radiation Protection in Industrial
Radiography
Regulation on Radiation Safety Inspections and Enforcements
Based on IAEA TECDOC Inspection of Radiation Sources and Regulatory Enforcement
Inspections in Industrial Radiography are carried out per one year according to tecdoc-1526.
Groups of minimum two inspectors.

18. Inspection in Industrial Radiography
Types of Inspections:
Pre-operational Inspections: After the company applies for license
Announced ( Informed) Inspections : The company is being informed before inspection. The purpose in this inspection is to discuss general safety procedures and documentation related to safety and security.
Unannounced (uninformed) Inspections: The purpose is to inspect how the safety procedures are carried out during on-job and in working areas. These inspections are made also according to complaint also.
Dose Related Inspections: These inspections are made related to information of high individual dose or when dose constraints are exceeded.

19. Inspection in Industrial Radiography
Radiation Safety and Security Inspectors:
All professions related to basic science: Physics engineers, physicists, chemists, nuclear energy engineers, etc.
Inspectors are choosed between the staff of Radiation Health and Safety Department.
Compulsory clauses : At least two years experience in the Department and he/she must been working in all other divisions of department in order to know all work done : licenseeng, import-export permission, trasportation and etc..
Candidate Inspector: After he/she begin to work in Inspection Division, during one year he/she attends many courses related to different radiological applications in industry and medicine. At the same time candidate inspector is observer and assistant to inspectors during inspections.

20. Inspection in Industrial Radiography
Radiation Safety and Security Inspectors:
Training process of candidate inspectors: It is written in Directive on Radiation Safety Inspection and Enforcement
Radiation Physics
Radiation Units, Radiation Detection Systems and Dosimetry
Biological effects of Ionising Radiation
Basic Safety Standarts
Basic Principles in Radiation Protection
Transportation of Radioactive Sources
End Life Management of Radiaoactive Sources and Waste Management
Applications in which Radiation Sources are used.
Types of exposure
Accidents and Emergency Response
Ethics and Responsibilities of Inspector.

21. Enforcement
Enforcement procedures are written and established in following documents:
Regulation on Radiation Safety
Regulation on Licensing and Radiation Protection in Industrial
Radiography
Regulation on Radiation Safety Inspections and Enforcements
The total of these documents cover all enforcement mattes we need. But mostly we use third one for enforcement after inspection.
Practical Guide for Enforcement and more detailed is:
Directive on Radiation Safety Inspections and Enforcement

22. Enforcement Directive on Radiation Safety Inspections and Enforcement
Defines the types and principles of inspection and gives the periods of inspection based on the type of application
Gives instructions to inspectors what to do and how to prepare before and after the inspection
Defines and states the enforcement type and procedures based on the non-compliance with regulations and directives.
Official letter including improprieties and deficiencies with regulations and gives instructions to the licensee.
Without time limit : This means that the improprieties and deficiencies must be completed until the next inspection.
Up to three months time limit: This means that improprieties and deficiencies must be completed and must be notified back to TAEA in three months. After the licensee’s official letter : inspection.
Temporary Cancellation of License: This means that the licensee is not allowed to use radiography application until the improprieties and deficiencies are completed and approved from TAEA.
Cancellation of License: This is made in case that licensee is not able to complete or keep the regulation or in very extreme cases when it is stated that the radation safety of the workers and public is not established by licensee.

23. THANK YOU FOR YOUR ATTENTION
Sinan Özgür
Radiation Safety Inspection Division
Radiation Health and Safety Department
Turkish Atomic Energy Authority (TAEA)