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HSE-SAF-PRO-00-0023

SAFETY MANUAL
Rev. 4
01-July-2012
RADIATION PROTECTION PROCEDURE
Page 1 of 50

TABLE OF CONTENTS

1. INTRODUCTION ................................................................................................. 2

2. SCOPE ................................................................................................................ 2

3. DEFINITIONS...................................................................................................... 2

4. PROCEDURE ..................................................................................................... 4

5. RESPONSIBILTIES .......................................................................................... 25

6. REFERENCES .................................................................................................. 28

ATTACHMENT......................................................................................................... 28

APPENDIX ............................................................................................................... 29

Amendment Prepared Reviewed Approved


Rev. Issue Date
Description By By by

Sara Khamis /
Carl
4 01-Jul-12 Refer to Appendix R Lloyd G Askham Amit Parikh
Poldrack
Carl Poldrack
Sara Khamis / Carl
3 04-Jul-11 Refer to Appendix R Lloyd G Askham
Amit Parikh Poldrack

2 04-Aug-10 Refer to Appendix R Lloyd G Askham

1 01-Mar-08 Refer to Appendix R Lloyd Askham

Next Scheduled Periodic Review: July 2013

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1. INTRODUCTION

Exposure to ionizing radiation; however small the amount, is presumed to involve some
risk. Radioactive sources are to be handled and used safely in order to minimise the risk
of radiation exposure to all personnel and the general public.

The instructions outlined in this procedure are not intended to detail working procedures
for radiation work. They detail the safety aspects within which the work shall be
conducted.

This procedure is designed to fulfil the requirements of:

• Decree Number 31 of 2002: Radiation Protection (Qatar).

• Occupational Safety and Health Administrations’ Ionizing Radiation Standard: OSHA


29 CFR 1910.1096

• Global OE Procedure EHS-5150, Radiation Safety Procedure.

2. SCOPE

This procedure is applicable to all Q-Chem employees and its contractors and describes
the minimum requirements to be followed to minimize the risk of exposure to ionising
radiation while transporting, handling, storing and using equipment containing radioactive
material. Q-Chem in this document refers to Q-Chem, Q-Chem II and RLOC.

This procedure covers the following:

• Analytical X-Ray Machines, e.g. X-Ray Fluorescence Analyzer.

• Devices Containing Radioactive Materials:

 Level / Density Transmitters

 Gas Chromatogram Analyzer # 5: Electron Capture Detector (ECD)

 Positive Metal Identification (PMI) Analyzers

• Industrial Radiography, e.g. Non Destructive Testing (NDT) work.

• Naturally Occurring Radioactive Materials (NORM).

3. DEFINITIONS

ALARA (As Low As Reasonably Achievable) means making every reasonable effort to
maintain exposures to radiation as far below the dose limits as is practical, taking into
account the state of technology, the economics of improvements in relation to state of
technology, and the economics of improvements in relation to benefits to public health
and safety.

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Controlled Radiation Area is an area, accessible to individuals, in which radiation levels


could result in an individual receiving a dose equivalent in excess of 1000µSv (1 mSv) in
1 hour at 30 centimeters from the radiation source or from any surface that the radiation
penetrates.

Curie (Ci) is a unit used to measure radioactivity. One curie is that quantity of a
radioactive material that shall have 37 x 109 disintegrations in one second.

“Classified Radiation Worker” means any employee who is likely to receive a dose of
ionising radiation which exceeds three-tenths (3/10) of the annual dose limit (i.e. >6
mSv).

Dose means the quantity of ionizing radiation absorbed, per unit of mass, by the body or
by any portion of the body.

Dosimeter is a device used to determine the external radiation dose a person has
received.

Effective Dose is the dose that takes into account the type of the organ that is being
exposed to radiation. The unit of measurement is Sievert (Sv).

Equivalent Dose is the dose that takes into account the type of radiation being absorbed
by the body tissue. The unit of measurement is Sievert (Sv).

“Non-classified Radiation Workers” means an employee who, as a result of his/her


work activities, is unlikely to receive a dose of ionizing radiation which exceeds three-
tenths of any relevant dose limit, but may receive a dose exceeding one-tenth (1/10) of
the annual dose limit (i.e. 2 mSv); i.e. greater than 2 mSv but less than 6 mSv.

Radiation (Ionizing Radiation) includes alpha rays, beta rays, gamma rays, X-rays,
neutrons, high-speed electrons, high-speed protons, and other atomic particles; but such
term does not include sound or radio waves, or visible light, or infrared or ultraviolet light.

Radioactive material means any material which emits, by spontaneous nuclear


disintegration, alpha or beta particles; gamma rays or neutrons.

Radiation Protection Officer (RPO) means a qualified technician designated by the


competent agency, or employed in the corporation which uses radioactive sources in
order to oversee the implementation of the prescribed radiation protection regulations
and give advice on radiation protection.

Sealed Source is a radioactive material that is permanently bonded or fixed in a capsule


or matrix designed to prevent release and dispersal of the radioactive material under the
most severe conditions which are likely to be encountered in normal use and handling
and which is used in that configuration.

Sievert is a unit used to derive a quantity called equivalent dose. This relates the
absorbed dose in human tissue to the effective biological damage of the radiation.
Equivalent dose is often expressed in terms of millionths of a Sievert, or micro-Sievert.
One Sievert is equivalent to 100rem (Roentgen).

Supervised Radiation Area is an area accessible to individuals, in which radiation


levels could result in an individual receiving a dose equivalent in excess of 50µSv (0.05

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mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the
radiation penetrates.

4. PROCEDURE

4.1. General Safety Precautions

4.1.1. All work involving sealed radioactive sources shall be carried out in accordance
with a Permit-To-Work (PTW) and Radiation Clearance Certificate (RCC)
system.

NOTE

All work involving Q-Chem owned radioactive sources shall commence


under the guidance of the Q-Chem RPO who shall designate a competent
person to work in his absence if required.

4.2. Radioactive Sources

4.2.1. A list of all radioactive sources used at Q-Chem is maintained by the Q-Chem
RPO.

• Attachment 3: “Radiation Source List – Mesaieed Complex”.

• Innov-X System Alpha 2000 XRF Analyzer, Serial Number 9567 – Ras
Laffan Complex

4.3. Radiation Protection Officer

4.3.1. The Q-Chem Radiation Protection Officer (RPO) shall oversee radiation safety
matters on site.

Mesaieed Complex

• The Industrial Hygienist is the appointed Radiation Protection Officer (RPO).

• The Industrial Hygiene Technician / Developee shall be appointed the


designated RPO in the absence of the Industrial Hygienist / RPO.

Ras Laffan Complex

• The Industrial Hygienist is the appointed Radiation Protection Officer (RPO).

• The Safety Specialist shall be appointed the designated RPO in the


absence of the Industrial Hygienist / RPO.

Note: These delegations shall be documented and retained on file for


review.

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4.3.2. The RPO shall have the following minimum qualifications:

• Specialized Training approved by the Ministry of Environment (MoE) on


Radiation Safety.

• Passed the RPO written exam conducted by the MoE.

• Be a fulltime Q-Chem employee.

4.4. Permissible Exposure Limits

4.4.1. Exposure to ionizing radiation shall be kept As Low As Reasonably Achievable


(ALARA).

4.4.2. Radiation exposure limits shall only be applicable to occupational exposure.

4.4.3. Exposures received from diagnostic, therapeutic, X-Ray machines for medical
treatment and background radiation, shall not be included in any of these
exposure limits:

Annual Maximum Permissible Dose Equivalent


Whole Body Dose Equivalent. 20mSv / annum (average over 5 years)
100mSv for any 5 consecutive years.
50mSv maximum allowed in a year
(aggregate in 5 years must not exceed
100 mSv)
Crystalline lens of the eye. 150mSv / annum
All other tissue organs (skin & 500mSv / annum
extremities).

4.5. Personnel Monitoring

Personnel monitoring is the measurement of radiation doses to persons in order to


ensure control of exposure to radiation.

4.5.1. Thermoluminescent Dosimeter (TLD) / Film Badge

• TLD or Film badges shall be required for each Classified Radiation Worker
where applicable.

• The TLD / Film badges shall be worn by Classified Workers at all times
when working with or handling radioactive materials.

 The badge shall only be worn by the individual to whom it was issued.

 The badge shall be worn on the body on outer clothing.

 Badges shall only be worn at work; i.e. they are for assessing
occupational exposure.
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 Badges shall not be worn during medical exposures, e.g. X-Rays.

• The TLD / Film badge shall be stored in a radiation-free area whenever it is


not in use.

• The badge shall not be left or stored in a highly humid environment, in high
temperatures or inside a vehicle.

• TLD / Film badges (when used) shall be returned to the Radiation


Protection Officer when requested.

4.5.2. Electronic / Pen Type Pocket Dosimeter

• Where applicable, all personnel entering and / or performing work that may
expose them directly or indirectly with a radioactive source shall be supplied
with either a pen type chargeable pocket dosimeter or a battery operated
electronic dosimeter.

 The dosimeters are not a substitute for TLD / Film badges that may be
issued to employees (Classified Radiation Workers).

 They shall be worn in conjunction with TLD / Film badges (for Classified
Radiation Workers only).

 They are not a substitute for suitable calibrated dose-rate monitors.

• Pocket dosimeters shall have a measuring range of 0-200mR (0-2mSv) and


the electronic dosimeter shall have the same or more.

• The pocket dosimeter shall be recharged to zero and the electronic


dosimeter reset to zero dose before the start of each radiation job.

• Each individual shall enter the dose received in the daily dose record after
completion of the job (see Attachment 2).

• If the pocket dosimeter goes out of scale or does not function properly, the
employee shall immediately stop all radiation work and contact the
applicable RPO to make a complete survey of the area for radiation
exposure levels.

 The job shall not be resumed until the defective dosimeter is replaced.

 The TLD badges (where used) of employees involved shall be


processed as soon as possible.

 The results (as applicable) shall be analyzed by the RPO before


allowing personnel to resume work.

• If the doses received by the employees engaged in radiation work or


working within the radiation area, are in excess of the maximum permissible
limits,

 The results shall be communicated to the affected employees,


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 The incident shall be investigated,

 The individuals involved shall be assigned to non-radiation work.

• If the dose received is within limits, individuals shall be allowed to resume


their work.

4.5.3. Medical Screening & Surveillance

Affected persons shall undergo medical screening & surveillance as below:

• Pre-assignment [Where Applicable]

 On joining Q-Chem or transferring to the role of Q-Chem Classified


Radiation Worker

• Periodic [Where Applicable]

 Annually for Q-Chem Classified Radiation Workers

• Emergency or Accidental Exposure [Where Applicable]

 On notification that an employee has been exposed above the


permissible exposure limits or published exposure levels in an
emergency situation or without necessary personal protective equipment
(PPE).

 As soon as possible after notification that an employee has developed


signs or symptoms indicating possible overexposure to radiation.

• Exit [Where Applicable]

 On leaving Q-Chem or when ceasing to be a Q-Chem Classified


Radiation worker.

 These medicals shall include, but shall not be limited to the following
tests:

 Fitness for duty

 Chest X-Rays

 Complete Blood Count (CBC)

Employee medical reports shall be maintained as per the Q-Chem Medical Records
Policy.

4.6. Radiation Survey Meters

4.6.1. No Industrial Radiography shall be permitted on the Q-Chem premises


WITHOUT a valid, calibrated, radiation survey meter being present. The survey
meter used shall satisfy the conditions listed below.
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4.6.2. Radiation survey meters used for monitoring shall be in good working condition
and measure within the applicable ranges:

• Industrial Radiography: At least 0-10mSv/h (10 000µSv/h or 1000mR/h).

• In-house surveys: At least 0-0.5mSv/h (500µSv/h or 50mR/h).

4.6.3. All survey meters used shall have a valid third party calibration.

• Calibration interval shall not exceed 12 months.

• A valid calibration certificate, or copy thereof (or proof of calibration) shall be


available for verification (by the Q-Chem RPO) with all survey meters used
on site.

4.6.4. In case of a survey meter becoming inoperable during radiation work; the area
shall be barricaded (if no barricades already available), and all work within that
area shall be suspended until a replacement meter is available.

• This includes work by Q-Chem employees working on Q-Chem equipment;


when applicable.

4.7. Signage & Demarcation

4.7.1. Each Supervised Radiation Area shall be conspicuously posted with a sign or
signs bearing the radiation caution symbol (Appendix E) and the words:

CAUTION

SUPERVISED RADIATION AREA

4.7.2. Where applicable; each Controlled Radiation Area shall be conspicuously


posted with a sign or signs bearing the radiation caution symbol (Appendix E)
and the words:

CAUTION

CONTROLLED RADIATION AREA

4.7.3. Each area or room in which radioactive material is used or stored and which
contains any radioactive material (other than natural uranium or thorium) in any
amount exceeding 10 times the quantity of such material specified in Appendix
C to 10 CFR part 20 shall be conspicuously posted with a sign or signs bearing
the radiation caution symbol (Appendix E) and the words:

CAUTION

RADIOACTIVE MATERIALS

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4.7.4. Each container in which is transported, stored, or used a quantity of radioactive


material (other than natural uranium or thorium) in any amount exceeding 10
times the quantity of such material specified in Appendix C to 10 CFR part 20
shall bear a durable, clearly visible label bearing the radiation caution symbol
(Appendix E) and the words:

CAUTION

RADIOACTIVE MATERIALS

NOTE

A room or area is not required to be posted with a caution sign because of


the presence of a sealed source, provided the radiation level 30
centimetres (12 inches) from the surface of the source container or
housing does not exceed 50µSv (5mR) per hour.

4.8. Storage of Radioactive Sources

4.8.1. The owner of the radioactive sources (Q-Chem / Contractor) shall be


responsible for the safe storage of all radioactive sources under his ownership.

4.8.2. The following conditions shall apply during the storage of radioactive sources
not in use:

• The shutter of the radioactive source shall be in closed position,

• The storage area shall be clearly marked with the radiation caution warning
sign (Trefoil) – see Appendix E.

• It shall be securely locked and the key must be kept by an Authorized


individual.

• No flammable, combustible or explosive material shall be kept near or


inside the storage area.

• The storage area shall be designed such that the dose rate on the outer
surface does not exceed 1µSv/hr.

• If this limit is exceeded the area around the store shall be marked off at the
7.5µSv/hr boundary and indicated by means of trefoils and warning notices.

• The store shall be monitored regularly by the relevant Radiation Protection


Officer and monitoring records shall be kept.

• Whenever a radioactive source is taken out of a store its movement shall be


detailed in a source register.

 The source register shall be kept by the relevant Authorized Person and
be available on request.

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 A copy of this register shall be forwarded to the Q-Chem RPO. The


register should include the following:

 Identification of the source

 The date of receipt on site

 The nature of radioactive substance

 The activity of radioactive substance

 The location of the radioactive substance

 The date the radioactive substance is taken off site.

• The Contractor RPO shall have an up-to-date inventory of all sources under
his / her control while at the Q-Chem site.

 This list shall be made available to the Q-Chem RPO if so requested.

4.9. Transportation of Radioactive Sources

4.9.1. A properly equipped and marked vehicle shall be used to transport shielded
equipment containing radioactive sources.

• General Public and Personal vehicles carrying passengers shall not be


used to carry radioactive sources.

• The vehicle shall be equipped with a suitable storage container in which the
radioactive package shall be placed during transport by road.

4.9.2. The transport vehicle shall be clearly marked with the following signage:

• Radiation warning symbol (vehicle placard) as illustrated in Appendix C,

• Radioactive source notice as illustrated in Appendix D of this document.

 The notice should carry the Owner Company Address

 Contact Number

 Business and home telephone numbers in case of emergencies.

4.9.3. The source container shall be marked with the radiation caution warning symbol
(Appendix E).

4.9.4. The relevant RPO is responsible for accompanying a radioactive source when it
is transported by road:

• To or from the Q-Chem Site.

• At all times while on the Q-Chem site (unless locked away as stated in
Section 4.11.9).
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4.9.5. Upon despatch or receipt (Materials Warehouse or other receiving location) of


any radioactive package at the Q-Chem site, the Q-Chem RPO / Designate
shall be informed. The RPO shall check the following:

• The documentation to ensure the correct source has been delivered.

• The source container for any damage.

• Ensure the Identification tag is attached to the source container.

• Carry out a radiation survey to check that the radiation intensity does not
exceed the following limits:

Maximum Surface Radiation Level Label Category

Not more than 5μSv/h Category I - WHITE

Between 5μSv/h and 500μSv/h Category II - YELLOW

Between 500μSv/h and 2000μSv/h Category III - YELLOW

• Complete a Radioactive Shipment / Receiving Form (Attachment 6) on the


same shift or day the shipment arrives on site.

4.10. Density / Level Transmitters

4.10.1. The gamma gauges are located in the Polyethylene Reactor Structures, i.e.
Trains 1, 2 and 3 (see Attachment 3):

Polyethylene Train 1 and 2:

• Fourteen (14) sources of Cesium-137 with level of radioactivity of 100mCi


(3.7GBq)

• Six (6) sources of Cesium-137 with level of radioactivity of 300mCi


(11.1GBq)

• Five (5) sources of Cesium-137 with level of radioactivity of 1000mCi


(37GBq)

Polyethylene Train 3:

• Two (2) sources of Cesium-137 with level of radioactivity of 50mCi


(1.85GBq)

• Six (6) sources of Cesium-137 with level of radioactivity of 100mCi (3.7GBq)

• Two (2) sources of Cesium-137 with level of radioactivity of 300mCi


(11.1GBq)

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• One (1) source of Cesium-137 with level of radioactivity of 1000mCi


(37GBq)

• Four (4) sources of Cesium-137 with level of radioactivity of 2000mCi


(74GBq)

4.10.2. These instruments are intended to remain in service for the lifetime of the plant.

• Routine maintenance of the receiver and calibration shall be done on site in


accordance with manufactures recommendations.

• If it becomes necessary to overhaul or replace the instrument it shall remain


sealed and shall be returned to the manufacturer for remedial work.

• This work shall be done under the instruction and supervision of


manufacturer’s representative who shall be designated as the Radiation
Protection Officer.

4.10.3. Any maintenance work that involves potential exposure to the radiation source /
beam shall be conducted while the shutter is in the OFF position and AFTER
confirmation that the device shutter is properly CLOSED.

4.10.4. The following two methods shall be utilized to confirm that the device shutter is
closed properly:

• Process control instrumentation (reading on DCS) shall be checked to


ensure that the readings from the radioactive source have decreased to
zero,

• A portable survey meter detector shall be placed in the beam path to


confirm the radiation reading has decreased to background levels and
levels are below acceptable limits.

4.10.5. Once the shutter is in the OFF position it shall be locked.

• Normal Lock Tag and Try (LT&T) procedures shall be followed.

• Under no circumstances, shall a person enter a piece of equipment with the


device shutter in the open position or if the shutter has not been properly
closed and placed under LT&T.

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4.11. Industrial Radiography

4.11.1. All work involving Industrial Radiography shall commence under the supervision
of a contractor-nominated Radiation Protection Officer who shall report to the
Q-Chem Designated Site Representative (DSR) / Designee.

4.11.2. A Permit To Work (PTW) shall only be initiated upon the completion of the
following:

• Radiation clearance (by obtaining Radiation Clearance Certificate) from Q-


Chem RPO / Designate.

• Job Safety Analysis (JSA) Meeting. The following items shall be discussed
and approved at the JSA meeting:

 Site-specific procedures,

 Site-specific emergency response plan,

 Any additional resources required for the job,

 Road blocking requirements if necessary,

 Sensitive equipment / instrumentation that may need protection during


radiography (i.e. need for additional lead sheeting),

 Planned start time of radiographic operations,

 PAGA announcements for regular plant emergencies,

 Radio availability and modes of communication between radiography


crew and permit issuer / DSR etc,

 List of the classified personnel (Contractor RPO as listed in the


Radiation Clearance Certificate) who shall work under the PTW.

4.11.3. The following are the minimum required personnel for the JSA:

• Permit Issuer, or

• Area operator for production areas (where applicable),

• Safety Representative or Fire & Safety Coordinator,

• The contractor’s Radiation Protection Officer (and Radiographers if


possible) who shall be involved with the job,

4.11.4. The Contractor’s Emergency Response Plan (ERP) shall be presented at the
JSA meeting for all Industrial Radiography work.

• The JSA shall not be concluded and signed off without the Emergency
Response Plan.

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4.11.5. A toolbox talk shall be conducted by the Contractor RPO / Lead Worker to
explain the permit conditions to all Classified Radiation Workers under the
permit.

• The content of the JSA shall be discussed with all Classified Radiation
Workers in the tool box talk (if Radiographers were not part of the initial
JSA) by the contractor RPO / Lead Worker.

• A copy of the JSA shall be available with the PTW / RCC at the entry point
to the Controlled Radiation Area by the contractor RPO.

4.11.6. The contractor RPO shall be present at all times at the worksite when the work
is being carried out.

• The RPO shall manage the Controlled Radiation Area at all times while
radiography is in progress.

• The work shall be carried out by a minimum of two Classified Radiation


Workers / Radiographers (excluding the RPO).

4.11.7. A “Controlled Radiation Area” shall be established for all Industrial Radiography
operations.

• Each source of radiation in use shall have a separate “Controlled Radiation


Area” boundary, with at least two radiographers allocated to work in the
radiography site.

 Only Classified Radiation Workers are to enter Controlled Radiation


Areas.

• The Controlled Radiation Area shall be surrounded by substantial barriers


or clearly visible ropes / ribbons marked with ‘Danger Radiation – Keep
Out’ placards for the safety of the Non-Classified persons, thereby
prohibiting their entry.

• It is the duty of the Contractor RPO to patrol / supervise the area and warn
Non-Classified persons from coming near this outer cordon.

• Barricade tape (of a bright colour e.g. yellow & black) and radiation signs in
Arabic and English, shall be used to cordon off Controlled Radiation Areas.

 The safe working distance shall be calculated for the radioactive source
strength being used and the demarcation barriers shall be positioned
accordingly prior to exposing the radioactive source.

 Radiation levels along the perimeter of the Controlled Radiation Area


shall not exceed 7.5µSv/hr.

 The position of the barriers may be altered after exposure, subject to


monitoring radiation levels (using a calibrated survey meter).

 Periodic radiation level measurements shall be taken at the demarcation


barriers to ensure that the radiation levels do not exceed 7.5µSv/hr.

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4.11.8. Whenever possible during radiography, the radiographer shall use collimators
to reduce the area affected by radiation.

• The collimator shall be firmly supported.

NOTE

All personnel entering Controlled Radiation Areas shall wear their TLD /
Film badges and Digital Radiation monitor / Dosimeter at all times and
shall be excluded if found not wearing them.

4.11.9. The exposure container shall not be left unattended at any time during
radiography.

• The exposure container / cameras shall be locked away in the appropriate


storage container on the transport vehicle.

• The Radiographer (Contractor RPO) shall keep the key of the locking
device until radiographic operations recommence.

4.11.10. Upon completion of the radiographic operations, the exposure container /


camera shall be locked and stored.

4.11.11. Monitoring shall be carried out to ensure the safe return of the source to its
container.

NOTE

No radiation work shall be permitted on the Q-Chem premises without a


valid radiation survey meter being present. See Section 4.6 for survey
meter specifications.

4.11.12. All radiographic work shall be suspended if any part of the equipment is noticed
to have become defective or damaged during radiographic operations.

• Work shall remain suspended until the equipment is replaced or repaired to


a safe operational condition.

4.11.13. Prior to the commencement of radiation work, the following steps shall be
taken:
• The DSR / Designee shall inform all relevant parties about the planned
radiation work including locations and timing

 Ideally this should be done at least 24 hours before commencement of


work

• The DSR / Designee shall ensure adequate representation on the JSA


team.

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• All permits within the Radiation Controlled Area or as specified by the Shift
Coordinator / Shift Supervisor (RLOC), shall be withdrawn prior to issuing
the permit for radiation work.

• Safe barrier distances shall take into account all working levels around
radiographic work.

• Public Announcement (see Appendix B) shall be made via the Q-Chem /


RLOC common radio channel 15 minutes prior to radiation work, advising
all affected personnel to make safe their workplaces and vacate the area.

• If operationally required, the radiation work can be stopped.

 The radiation source shall be made safe,

 The safety barriers removed,

 The work permit / radiation clearance certificate returned to the Shift


Coordinator / Shift Supervisor (RLOC).

The entire procedure as stated above shall be repeated when recommencing


radiation work.

• If the radiation interruption is of a short period (e.g. to take pressure


readings), the radioactive source shall be made safe.

 The Radiation worker shall return the work permit / radiation clearance
certificate to the Shift Coordinator / Shift Supervisor (RLOC) and remove
only one barrier.

 The Radiation worker shall then remain close to the removed barrier
point and keep a strict control of personnel movement into the restricted
area.

• Radiation work can be resumed after people have cleared the restricted
area and all barriers reinstated, and the Radiation worker has the work
permit / radiation clearance certificate in his possession.

CAUTION
Under no circumstances shall persons other than the classified
radiation workers cross the safety barrier during radiographic
operations!

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4.12. Naturally Occurring Radioactive Materials [NORM]

4.12.1. Quantitative measurements (by Q-Chem RPO / Designate) for radioactivity


shall be conducted on equipment anticipated to potentially be contaminated /
contain N.O.R.M when such equipment is opened for maintenance. Such
equipment may include but is not limited to the following:

• AGRU – Metering Skid / CO 2 Absorber outlet


• Furnace Feed Header
• Quench Tower – CG Suction / Oily Water Separator
• De-ethanizer [02-95-204] and associated equipment
• De-propanizer [02-95-207] and associated equipment
• Fuel oil drum
• PRC refrigeration circuit.
• C3 Storage bullet
• C3 Transfer Pump.

Specific maintenance activities on the following equipment:

• Reboiler cleaning of De-ethanizer [02-95-204] and De-propanizer [41-


12/12A] and [41-45/45A].
• Maintenance activities for Fuel oil pump [67-25/25A]
• ERG metering skid upstream and downstream block valve s to be replaced
• CGC Intercoolers [41/15, 41/18]
• De-ethanizer Feed Chiller [41/22]
• De-ethanizer Reboiler outlet block valves to be replaced.
• De-ethanizer tray 9 temp indication 02-TI-71184

4.12.2. When the equipment suspected of containing N.O.R.M. is opened or


disassembled, care is needed to preclude radioactive particles from being
inhaled or ingested.

• Any levels of gamma radiation exceeding 0.05mR/hr or greater than 1000


dpm shall be identified with signs indicating radioactive material.

• All other N.O.R.M. containing equipment shall be posted / labelled as


containing N.O.R.M.

4.12.3. This survey shall also be performed to verify if equipment can be shipped to an
offsite facility for maintenance / repair.

4.12.4. An appropriate N.O.R.M Control Program shall be developed if radiation levels


exceed prescribed limits (see Appendix J).

4.12.5. Entry into vessels suspected of containing NORM, any welding on NORM-
contaminated equipment, or any abrasive work (e.g., scraping, grinding, buffing,
polishing, etc.) of NORM-contaminated equipment requires additional PPE
which at a minimum shall include, but is not limited to, the following:

• *Half-face respirator with HEPA cartridges, e.g. P-100.

• Disposable paper coverall.

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• *Disposable boot covers or Rubber Boots.

• Safety glasses.

• Neoprene rubber gloves [If leather gloves are used, e.g. due to
requirements of task, they must be disposed of after use).

* Not required if the N.O.R.M. is not removable and no maintenance activities


shall cause the N.O.R.M. to become airborne. These are activities such as,
cutting, grinding, buffing, machining, chiselling or drilling.

4.12.6. Employees working on contaminated equipment shall not eat, smoke, and
drink, etc. while engaged in such activities.

4.12.7. Skin contact shall be avoided with interior surfaces where practicable.

4.12.8. All workers involved with such equipment shall be required to wash their hands
thoroughly with soap and warm water before smoking, drinking, eating, etc. and
at the end of work.

• Washing shall be complete to the point where no evidence of material is


present, i.e., no evidence of discoloration on skin.

• This shall take 1.5 to 2 minutes.

4.12.9. Gloves, respirator cartridges, disposable clothing and rags used on suspected
contaminated equipment shall be put into plastic bags, sealed and tested by the
Q-Chem RPO to determine disposition.

4.12.10. Every effort shall be made in the preparation of N.O.R.M. containing equipment
for maintenance that personnel exposure is kept AS LOW AS REASONABLY
ACHIEVABLE (ALARA). This can be accomplished by purging, steaming, and
time (allowing items to stand for a long period).

4.12.11. Any item removed from contaminated equipment, (i.e. pump packing, mil scale,
etc.), shall be put into plastic bags, sealed, and tested by the Q-Chem RPO /
Designate to determine disposition.

• No items removed from contaminated equipment shall be placed in a scrap


metal or trash dumpster without a radiation survey by the RPO / Designate.

NOTE

The levels of N.O.R.M. found in process equipment can vary with feed
stocks; therefore it may not be present in a piece of equipment one time
and present the next. No assumptions shall be made.
Refer to Appendix J for guidelines on N.O.R.M.

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4.13. Radiation Clearance Certificate

4.13.1. A Radiation Clearance Certificate (RCC) shall be obtained prior to any


maintenance work that may expose personnel directly or indirectly with a
radioactive source. Such tasks may include, but are not limited to the following:

• Removing / replacing the shutter / rotor,

• Removing / replacing or drilling on the shutter closing mechanism / lever,

• Removing any outer components that normally conceal the source / source
holder,

• Vessel Entry into equipment that has a device containing a radioactive


source,

• Maintenance on XRF analyzer.

Contact the Q-Chem RPO / Designate for tasks not listed in this document!

4.13.2. The Contractor’s Radiation Safety Manual (RSM) together with all the
necessary certifications of the affected radiation workers shall be presented and
reviewed by the Q-Chem RPO for all industrial radiography work before the
RCC can be issued.

• Updated / Revised RSM’s shall be forwarded to Q-Chem RPO when


available.

• Company’s that have already submitted such documents to Q-Chem in the


past need only present current certifications of personnel. These
documents shall be submitted to Q-Chem RPO for record keeping
purposes.

4.13.3. No radiation clearance certificate shall be issued when working with exposed
radioactive sources / materials if there is no RPO to supervise the operation.

• The Contractor RPO shall be physically present at worksite for all Industrial
Radiography.

• Q-Chem RPO / Designate shall be contactable / reachable for all Q-Chem


radiation jobs where a radiation clearance certificate is required.

4.13.4. A Radiation Clearance Certificate [RCC] is not required for maintenance-related


tasks where the sealed radioactive source is not directly / indirectly exposed to
personnel, i.e. general / routine work on the outer surface of Level / density
transmitter gauges. Such tasks may include, but are not limited to the
following:

• Shutter closing / opening as part of normal Lock Tag & Try (LT&T)
procedures,

• Calibration or troubleshooting of nuclear gauge control instrumentation,

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• Planned Maintenance (PM) on the outer surface of the gauge, e.g. cleaning
or applying lubricants for the shutter closing mechanisms.

Contact the Q-Chem RPO / Designate for tasks not listed in this document!

4.13.5. The RCC shall be posted together with the PTW at the entry point of the
radiation work area (boundary of entry point) with the following attachments:

• Copy of JSA

• Copy of the Emergency Response Plan

The RCC is provided as Attachment 1 to this procedure.

4.13.6. Certificate Validity

• The RCC is only valid for the duration authorized on the certificate provided
there is no change in job scope or Radiation Protection Officer.

 The RCC shall be re-validated or re-issued by the Q-Chem RPO for any
changes to the original scope.

NOTE

A Radiation Clearance Certificate [RCC] Is Mandatory For All Industrial


Radiography.

4.13.7. Job Completion and RCC Closure

• When radiation work is completed or stopped for the day, the contractor
RPO shall notify the Lead Worker or Work Permit Issuer, i.e. Area Operator
or Area representative.

• The RCC shall be removed from the field.

• The Permit Issuer shall carry out a joint inspection of the work area along
with the Contractor RPO and verify that all radioactive materials / sources
have been safely retrieved and the area is safe.

 The Contractor RPO (Industrial Radiography) shall scan the work area
with the radiation survey meter to ensure no significant radiation dose
rates are detected.

 The radiation clearance survey dose rates shall be recorded on the RCC
(as required on the RCC) before the PTW is closed out.

• The Contractor RPO (receiver of the RCC) shall deliver the completed RCC
to the Q-Chem RPO / Designate for final closure. The following
documentation / equipment shall be returned with the RCC when applicable:

 Employee’s Personal Dose Record form (where applicable),

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 Any Q-Chem monitoring devices issued at start of task.

• The Q-Chem RPO shall retain the closed out RCC for a minimum period of
one (1) calendar year.

NOTE

A Radiation Clearance Certificate for radioactive source isotopes in


excess of 25 curies (25Ci) shall require Plant manager approval in
consultation with Q-Chem RPO.

4.14. Emergency Response

4.14.1. All users of radioactive materials shall be familiar with the Emergency
Response Procedures before any emergency arises.

4.14.2. Refer to Appendix A for Q-Chem Emergency Contact Details for dealing with
radioactive materials.

• The Contractor’s Emergency Response Plan shall be followed during


Industrial Radiography activities on the Q-Chem site.

 This Plan shall be discussed during the JSA meeting.

 The appointed contractor RPO shall have operational control for


handling / dealing with the radioactive material.

 The Q-Chem Fire and Safety Coordinator (Incident Commander) shall


have overall functional / strategic control of the incident on the Q-Chem
site.

4.14.3. If a gas detector alarms or the plant alarm sounds at any time during the job:

• The PTW and RCC is Cancelled.

• Work shall be stopped immediately.

• Equipment shall be turned off and secured as quickly as possible.

• Personnel shall leave the area proceeding to nearest assembly point.

• The contractor RPO or Lead worker shall notify the Permit Issuer.

4.15. Incident and Near Miss Reporting

4.15.1. The Q-Chem “Incident Reporting and Investigation Procedure” shall be followed
in reporting and investigating an incident (or near miss) involving radioactive
materials.

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4.15.2. The Q-Chem RPO or designate shall be notified promptly of all accidents,
incidents, or near misses involving the following scenarios:

• Possible, personnel overexposure to radiation,

• Possible personnel or area contamination with radiation,

• Failure (s) or malfunctioning of any radiation equipment safety devices,

• Detachment / loss of a radioactive source.

4.15.3. In case of a real overexposure, the applicable RPO [Q-Chem RPO or


Contractor RPO when applicable] shall report the incident to the Ministry of
Environment (MoE).

4.15.4. In addition, the Q-Chem RPO / Designate shall report IMMEDIATELY to the
Corporate RSO within the Corporate EHS organization by telephone of any
incident involving radiation which may have caused or threatens to cause:

• Exposure of the whole body of any individual to 25rems [0.25Sv / 250mSv]


or more of radiation;

• Exposure of the skin of the whole body of any individual to 150rems [1.5Sv /
1500mSv] or more of radiation;

• Exposure of the feet, ankles, hands, or forearms of any individual to


375rems [3.75Sv / 3750mSv] or more of radiation; OR

• The release of radioactive material in concentrations which, if averaged


over a period of 24 hours, would exceed 5,000 times the limit specified for
such materials.

4.15.5. The Q-Chem RPO / Designate shall report by telephone within Twenty-four
(24hrs) to the Corporate RSO of any incident involving radiation which may
have caused or threatens to cause:

• Exposure of the whole body of any individual to 5rems [0.05Sv / 50mSv] or


more of radiation;

• Exposure of the skin of the whole body of any individual to 30rems [0.3Sv /
300mSv] or more of radiation;

• Exposure of the feet, ankles, hands, or forearms to 75rems [0.75Sv /


750mSv] or more of radiation; OR

• "Reports of overexposure and excessive levels and concentrations."

NOTE

The Q-Chem RPO shall also notify such individual of the nature and
extent of exposure. This notice shall be in writing and shall contain the
following statement:
"You should preserve this report for future reference."

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4.16. Record Keeping

4.16.1. All records documenting compliance with this procedure shall be kept in the Q-
Chem office or as indicated in the applicable sections of this procedure.

4.16.2. Where applicable; a list of all Classified Radiation Workers shall be maintained
by the Q-Chem RPO.

4.16.3. Records of the results of surveys and personnel (where applicable) radiation
exposure monitoring shall be maintained for the life of the facility.

4.16.4. Radiation survey meter calibration and maintenance records shall be available
on request from the Q-Chem RPO.

• The applicable contractor’s RPO is responsible for updating & maintaining


their records and making them available to Q-Chem RPO when so required.

4.16.5. Records of all Radiation Clearance Certificates (RCC) shall be maintained by


the Q-Chem RPO for duration of one (1) calendar year.

4.17. Training

4.17.1. No individual shall use radiation producing equipment or work with


radioisotopes without training.

4.17.2. Training is necessary to ensure that safe work practices are followed, to
prevent overexposure of the operator and others, and to avoid contamination of
the surroundings.

4.17.3. Employees who during the normal course of their duties are required to perform
radiation-related tasks in “Controlled or Supervised Radiation Controlled Areas”
shall at a minimum receive annual training in the following areas:

• Storage, transfer, or use of radiation sources / equipment;

• Health risks and symptoms associated with exposure to radiation sources /


equipment;

• Precautions or procedures to minimize exposure;

• Purposes and functions of protective devices employed;

• Controls that workers may employ to minimize radiation exposure;

• The applicable provisions of regulations and licenses for the protection of


personnel from exposure to radiation sources / equipment;

• The responsibility to report promptly to the licensee any condition which


may lead to or cause a violation of regulations / licenses or which may lead
to the unnecessary exposure to radiation and/or radioactive material;

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• The appropriate response to warnings made in the event of any unusual


occurrence or malfunction that may involve exposure to radiation sources /
equipment; and,

• The radiation exposure reports which workers may request.

4.17.4. Specific issues in the operation of the various instruments, e.g. PMI and XRF
spectrometer, shall be provided within the applicable workgroup by
appropriately experienced personnel, the equipment / instrument vendors or
under their guidance.

4.17.5. The general Q-Chem population / Baseload Contractors shall receive a


Radiation General Awareness Course annually.

• The content of this training course shall be determined by the Q-Chem


RPO.

4.17.6. All training required by this procedure shall be documented.

4.18. Program Review

4.18.1. Program reviews shall be conducted at least annually, with time between
reviews not to exceed twelve months.

4.18.2. A change review team (CRT) comprising of affected stakeholders shall be


formed to conduct the reviews.

4.18.3. The following items shall be addressed during the review process:

• Records of any incidents or near misses involving Ionizing Radiation


exposure.

• Lesson learned reports from other CPChem affiliate facilities.

• Any audit findings from the previous twelve month period.

• Legislation changes, including changes to the Global OE procedure EHS-


5150, Radiation Safety.

• New work practices or work locations (if any) involving potential exposure to
Ionizing Radiation sources.

• Review of the Radiation Protection training modules

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5. RESPONSIBILTIES

5.1. Q-Chem Radiation Protection Officer

5.1.1. Prepare the Radiation Protection Procedure and facilitate its review.

5.1.2. Assign RPO responsibilities to suitable designate in his / her absence.

5.1.3. Authorize radiation clearance certificates for all radiation work at Q-Chem.

5.1.4. Conduct radiation surveys, audits & sealed source wipe tests where required.

5.1.5. Manage and monitor the usage and interpretation of electronic radiation
dosimeters used by Q-Chem employees.

5.1.6. Inspect and clear all items arriving / received at the Q-Chem site that contain
radioactive materials.

5.1.7. Advise Q-Chem on radiation safety matters.

5.1.8. Report on radiation safety incidents to the Ministry of Environment (MoE) and
the Corporate RSO within the Corporate EHS organization.

5.1.9. Develop and provide Radiation Safety Training to affected end users.

5.1.10. Ensure contractor radiography service providers used on site are made familiar
with the requirements of the Q-Chem Radiation Protection Procedure.

5.1.11. Maintain all records pertaining to radiation monitoring.

5.2. Designated Site Representative (DSR) or Designee / Area Supervisor

5.2.1. Ensure a copy of this procedure is presented to the radiography contractor prior
to the JSA meeting.

5.2.2. Ensure adequate notice is given to affected stakeholders regarding any


Industrial Radiography scheduled for the Q-Chem site.

5.2.3. Inform the Q-Chem RPO / Designate regarding the expected arrival of any
radioactive materials at the Q-Chem premises.

• This includes contractor radiography service providers arriving on the Q-Chem


site with radio-isotopes / X-ray sets.

5.2.4. Ensure the JSA has been completed before the issuance of a PTW.

• Ensure there is an adequate representation on the JSA team.

• Ensure contractor radiography service provider has all the necessary


documentation before arrival on the Q-Chem site for Radiation Clearance
Certificate & JSA meeting.

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• Ensure the JSA is communicated during the toolbox talk to the affected
employees.

5.3. Contractors / Radiography Service Providers

5.3.1. Meet all procedural and documentation requirements as per the radiation
protection procedure.

5.3.2. Meet all requirements as stated on the Radiation Clearance Certificate (RCC).

5.4. Radiation Workers (Classified & Non-classified)

5.4.1. Be familiar with all emergency response procedures related to radiation safety
at Q-Chem.

5.4.2. Ensure they have received radiation safety training before working with
radioactive materials / equipment.

5.4.3. Wear an electronic radiation dosimeter (where applicable) at all times when
entering or working in a designated radiation area.

• Controlled Radiation Area

 Entering a vessel fitted with a density or level transmitter.

 Entering the demarcated boundary during Industrial Radiography.

• Supervised Radiation Area

 During all RCC-required radiation tasks (as listed in Section 4.13.1)


within the demarcated areas around vessels at the PE Reactor
structures.

5.4.4. Report any incidents or near misses involving radioactive materials:

• Immediately to the Q-Chem RPO / Designate

• Follow the Q-Chem “Incident Reporting & Investigation Procedures”

5.4.5. Follow the requirements of this procedure as applicable to them.

5.5. Radioactive Material Owners

5.5.1. Ensure proper storage (where applicable) and maintenance of all equipment &
instruments containing radioactive sources.

5.5.2. Ensure all radiation-containing sources / equipment is clearly identified with


suitable hazard warning signs

• Keep a local register of all radiation-containing sources / equipment

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• Forward all such records & updates to the Q-Chem RPO

5.5.3. Provide training on the safe use of equipment / instruments containing


radioactive materials to all employees required to use such instruments /
equipment.

5.5.4. Ensure all radiation safety signage / labelling requirements are fulfilled within
their affected areas.

5.5.5. Complete a Radioactive Shipment / Receiving Form (Attachment 6) before


shipping or receiving any radioactive source-containing equipment.

5.5.6. Consult with the Q-Chem RPO / Designate when necessary or if requiring
clarification on matters pertaining to radiation safety.

5.6. Fire & Safety Co-ordinator (FSC)

5.6.1. Oversee the overall site Emergency Response Plan.

5.6.2. Liaise with the contractor RPO during any emergency situations that may arise
during industrial radiography work on the Q-Chem premises.

5.7. Medical Services

5.7.1. Where applicable; schedule and conduct medical screening and surveillance for
Q-Chem Classified Radiation Workers and anyone requiring surveillance in an
emergency situation.

5.7.2. Maintain all employee medical records as per Q-Chem Medical Records Policy.

5.8. Materials Warehouse

5.8.1. Contact the Q-Chem RPO / Designate when receiving any items containing
radioactive materials

5.9. Training

5.9.1. Ensure the Radiation Protection Procedure (CBT-based module) is assigned to


users.

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6. REFERENCES

• Decree Number 31 of 2002: Radiation Protection: Ministry of Environment (MoE),


Qatar.

• Title 29 of the Code of Federal Regulations, Section 1910.1096, Ionizing Radiation


(OSHA).

• US Nuclear Regulatory Commission Regulations Title 10 of the Code of Federal


Regulations, Part 20, Standards For Protection Against Radiation: Appendix C

• Chevron Philips’ Corporate Radiation Safety Procedure: Document Number EHS-


5150.

ATTACHMENT

Attachment 1 – Radiation Clearance Certificate (RCC)

Attachment 2 – Personal Dose Record

Attachment 3 – Radiation Source List – Mesaieed Complex

Attachment 4 – X-Ray Machine Inspection Form

Attachment 5 – Radioactive Source Inventory And Maintenance Inspection Form

Attachment 6 – Radioactive Shipment / Receiving Form

Attachment 7 – Radiography Contractor Onsite Audit Form

Attachment 8 – Sealed Source Wipe Sampling Standard [HSE-SAF-STD-00-0015]

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APPENDICIES

Appendix A – Contact Details for Radiation Sources

Appendix B – Public Announcements

Appendix C – Vehicle Placard (Warning Sign)

Appendix D – Radioactive Source Notice (Transport Vehicles)

Appendix E – Radiation Caution Symbol (Trefoil)

Appendix F – Devices Containing Radioactive Material

Appendix G – Analytical X-Ray Machines

Appendix H – Industrial Radiography

Appendix I – How To Determine Annual Radiation Exposure

Appendix J – Naturally Occurring Radioactive Material (NORM)

Appendix R – Amendment History

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APPENDIX A: Q-CHEM CONTACT DETAILS FOR RADIATION SOURCES

MESAIEED SITE

Radiation Protection Officer (RPO) Designated Radiation Protection Officer (RPO)


Lloyd Askham Ferdinand L Santos
Industrial Hygiene Specialist Industrial Hygiene Technician
Safety & Fire Department Safety & Fire Department
Qatar Chemical Company Ltd. Qatar Chemical Company Ltd.

Tel: 4476-7348 (Office) Tel: 4476-7320 (Office)


Tel: 4476-2891 (Home)
Mobile: 556-22-715 Quality Control Laboratory
Dr Akmal Rana
Laboratory Superintendent
Technical Department
Qatar Chemical Company Ltd.

Equipment Reliability Group Polyethylene Units


Mr Umesh Choondassery Hitesh Patel & Job S Jeyapandian
Superintendent Superintendent
Technical Department Production
Qatar Chemical Company Ltd. Qatar Chemical Company Ltd.

Materials Warehouse Safety & Fire Section


Ibrahim A Rabieh Carl H. Poldrack
Warehouse Senior Supervisor Safety Manager
Qatar Chemical Company Ltd. Safety & Fire Department
Qatar Chemical Company Ltd.

RAS LAFFAN SITE

Radiation Protection Officer (RPO) Designated Radiation Protection Officer (RPO)


Amit Parikh Abdul W Sheikh
Industrial Hygienist Safety Specialist
HSE Department HSE Department
Ras Laffan Olefins Company (RLOC). Ras Laffan Olefins Company (RLOC).

Tel: 4457-2396 (Office) Tel: 4457-2390 (Office)


Mobile: 335-16-467 Mobile: 338-93-466

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APPENDX B: PUBLIC ANNOUNCEMENT

NOTE: The following P.A. Announcement SHALL be made 15 minutes before the
scheduled Radiography begins.

 ATTENTION – THIS IS A RADIOGRAPHY ANNOUNCEMENT.

[REPEAT TWICE MESSAGE BELOW]

RADIOGRAPHY SHALL COMMENCE AT. . . . . . . . . . . . . . . . . . . . (LOCATION)


IN 15 MINUTES.

ALL PERSONNEL MUST LEAVE THE AREA IMMEDIATELY. DO NOT CROSS


ANY OF THE SAFETY BARRICADES

NOTE: The following P.A. Announcement SHALL be made when Radiography is


completed.

 ATTENTION – THIS IS A RADIOGRAPHY ANNOUNCEMENT.

[REPEAT TWICE MESSAGE BELOW]

RADIOGRAPHY IS COMPLETED AT. . . . . . . . . . . . . . . . . . . . . . . (LOCATION).

ALL CLEAR!

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APPENDIX C: VEHICLE PLACARD (WARNING SIGN)

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APPENDIX D: RADIOACTIVE SOURCE NOTICE (TRANSPORT VEHICLES)

This vehicle is carrying

RADIOACTIVE MATERIALS

In the event of Emergency situations, please contact the following:

NAME OF TRANSPORT COMPANY:


ADDRESS:

Tel:

Fax:

Applicable Radiation Protection Officer

NAME:
Tel Office:
Tel Home:
Bleep:
Mobile Phone:

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APPENDIX E: RADIOACTIVE SOURCE NOTICE (TRANSPORT VEHICLES)

This symbol must be printed in COLOR when used.

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APPENDIX F: DEVICES CONTAINING RADIOACTIVE MATERIAL

F1. Description

Fixed devices containing a sealed source of radioactive material mounted on process


equipment are used in production units as level or density alarms or indicators in
various processes involving liquids and solids. A radiation detector is mounted on one
side of a vessel while a radiation source (device) is positioned on the opposite side. A
variation in level or density within the process vessel causes a change in the radiation
detector reading. The radiation device then signals the level or density change to the
process control operator for action(s), as applicable.

Portable devices containing sealed sources of radioactive material are also typically
used in Positive Material Identification (PMI) programs.

F2. Licensing

Radioactive material devices can be licensed as either “specifically licensed” or


“generally licensed.” The two license categories are further described below:

1. Specific License

• The manufacturer, model number, isotope, activity and authorized use must be
listed on the user’s specific license before the manufacturer shall distribute the
device.

• The licensee may be authorized by the licensing agency to install and remove
fixed devices. Refer to the site specific license and read the conditions of the
license.

2. General License

• The manufacturer can distribute the device without the user having a license.
The licensing agency regulations may require the user to acknowledge the
possession of the device depending on the isotope and activity of the device.
Typically most licensing agencies allow 30 days from the receipt date of the
device for the user to make this acknowledgment in writing to the agency.
Check with local regulations to ensure compliance with this requirement.

• The user is not authorized by a licensing agency to install or remove fixed


devices. Refer to the manufacturer user’s manual for specific tasks the user
can perform related to this device.

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F3. Procurement

The following steps are required to purchase a device containing radioactive material:

• The site RPO must be notified of any plans to purchase a device before
initiating the purchase.

 The RPO notification must include the device manufacturer, model number,
isotope, activity, and intended use.

• The RPO shall initiate all license amendments to add radioactive materials.
Applying or amending a specific license may take several months.

 The RPO shall notify the Material Warehouse if item is approved.

• The facility shall initiate Management of Change requirements in accordance


with Operational Excellence System Element 2.7 when devices containing
radioactive materials are installed, relocated, or removed from service within the
facility.

F4. Receiving Radioactive Material

The RPO or designee must survey, perform a leak test on each device, and complete a
Radioactive Shipment / Receiving Form (Attachment 8) or equivalent if dictated by a
local regulation, on the same shift or day the shipment arrives at the licensee’s site.

F5. Temporary Storage of Devices Containing Radioactive Material

Devices not going immediately into service shall be secured to prevent unauthorized
removal. Devices in temporary storage shall have a “CAUTION RADIOACTIVE
MATERIALS” sign posted and be stored in a designated storage area, keeping in mind
personnel exposure needs to be As Low As Reasonably Achievable (ALARA).

F6. Installation of Devices Containing Radioactive Material

If the licensee is authorized to install devices containing radioactive material,


installation instructions provided from the licensing agency shall be followed. If the
licensee does not have procedures for installing devices containing radioactive
material, the device shall NOT be installed; a licensed third-party contractor shall be
contacted to perform the installation process using authorized procedures.

F7. Semi-Annual Inspections

1. At intervals not to exceed six months, each device containing radioactive material
shall be visually inspected and inventoried.

• Records documenting the visual inspection and inventory shall be maintained


by the licensee for inspection by the regulatory agency.

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2. Visual inspection shall include verification of the following:

• The source label is legible,

• The source has a “Caution Radioactive Material” sign,

• The device is mounted correctly, and

• The on/off shutter mechanism functions properly.

3. All inspections shall be completely documented using Radioactive Source Inventory


and Maintenance Inspection Form (Attachment 7) or equivalent if dictated by a
local regulation.

F8. Sealed Source Wipe Tests

1. Sealed source wipe tests shall be performed per the device registry (Attachment 3
– Radiation Source List for details) for each device containing radioactive material.

• The registry can be obtained from the manufacturer, to determine the interval
for performing sealed source wipe tests.

2. The wipe of a sealed source shall be performed using a wipe test kit or method
[see Attachment 10 – “Sealed Source Wipe Sampling Standard” HSE-SAF-STD-
00-0015] approved by the licensing agency or authority having jurisdiction.

3. The wipe sample shall be taken from the nearest accessible point to the sealed
source where contamination might accumulate.

4. The wipe sample shall be analyzed for radioactive contamination.

• The analysis shall be capable of detecting the presence of 0.005 microcuries of


radioactive material on the test sample and must be performed by a person
approved by the licensing agency or authority having jurisdiction
• Sealed source wipe test kits shall be obtained from and analyzed by Suntrac
Services, Inc. or an equivalent vendor approved by the Corporate RSO

F9. Vessel Entry

1. If entry is required into a vessel or piece of equipment that has a device containing
a radioactive source, the radioactive source must be considered a source of energy
and the device shutter must be placed in the closed position.

2. To eliminate unintentional exposure to radiation, the device must then be locked


and tagged out per the facility’s local energy isolation (lockout / tagout) procedure.

• Under no circumstances, shall a person enter a piece of equipment with the


device shutter in the open position or if the shutter has not been properly closed
and locked / tagged out.

3. The following two methods shall be utilized to confirm that the device shutter is
closed properly:
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• Process control instrumentation shall be checked to ensure that the readings


from the radioactive source have decreased to zero.

• A portable survey meter detector shall be placed in the beam path to confirm
the radiation reading has decreased to background levels and levels are below
acceptable limits.

F10. Removal of Devices Containing Radioactive Material

1. If the licensee is authorized to remove devices containing radioactive material, the


removal procedures submitted to the licensing agency shall be followed.

2. If the licensee does not have procedures for removing devices containing
radioactive material, the device shall NOT be removed.

3. A licensed third party contractor shall be contacted to perform the removal process
using authorized procedures.

F11. Storage of Devices Containing Radioactive Material

1. All devices containing licensed radioactive material shall be stored in a manner that
limits radiation exposure to members of the general public and prevents
unauthorized removal of the devices from the storage location.

2. Each storage location shall have a “CAUTION RADIOACTIVE MATERIALS” sign to


communicate that radioactive material is present.

3. This area and all sources kept within shall be included in the documented semi-
annual inspection.

F12. Shipping Devices Containing Radioactive Material

1. Prior to shipping radioactive material, the licensee shall obtain a return


authorization number and a current copy of the receiving company’s license to
verify the receiving company is authorized to possess the material.

2. The shipment must be packaged, labelled, and have all paperwork completed in
accordance with all applicable local regulations.

3. The RPO must survey the shipment and complete the Radioactive Shipment /
Receiving Form (Attachment 8) or equivalent if dictated by a local regulation.

4. The shipping form should accompany other required shipping papers such as the
Bill-of-Lading (BOL) containing the proper regulatory shipping description.

5. The licensee must receive a letter of transfer from the company receiving and
possessing the radioactive material.

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F13. Radiation Worker Annual Radiation Exposure

1. The maximum exposure limit for a Radiation Worker is 50 000 µSv/yr [50 mSv/yr].

2. Each licensee is required to document each radiation worker’s exposure if the


worker is issued a personnel radiation badge.

• If a licensee can document that it is unlikely that a radiation worker would


receive 10% or less of the annual limit in a calendar year [5000 µSv/yr or
5mSv/yr], the licensee is exempt from personnel monitoring. Refer to “How to
Determine Annual Radiation Exposure” (see Appendix I).

• If a radiation worker declares her pregnancy to the RPO, the exposure limit is
5000 µSv for the term of the pregnancy.

F14. Members of the General Public Radiation Exposure

The exposure limit for members of the general public is 1000 µSv/yr [1
mSv/yr]. Each licensee is required to document that members of the general
public shall not exceed this exposure limit. Refer to “How to Determine
Annual Radiation Exposure” (see Appendix I).

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APPENDIX G: ANALYTICAL X-RAY MACHINES

G1. Description

Various types of analytical instruments or machines use X-ray radiation for material
testing. Two common types of analytical instruments are X-ray fluorescence (XRF)
machines and X-ray diffraction (XRD) machines. The difference and their respective
levels of threat are described below:

1. Minimal Threat Machines

• X-ray fluorescence machines are equipped with a closed beam configuration


with interlocks that immediately shut down the beam before personnel can be
exposed to the beam.

2. Non-Minimal Threat Machines

• X-ray diffraction machines are equipped with an open beam configuration,


meaning that an individual could accidentally place some part of his or her body
in the primary beam path during normal operation.

G2. Registration

1. Registration of X-ray producing machines may not be required by all agencies. Any
registration requirements must be verified by the RPO with the local regulatory
agency having jurisdiction.

2. The RPO is responsible for initiating the registration process in accordance with the
following requirements as appropriate:

• Amend the registration to include any new X-ray machine within 30 days of
initial operation.

• Amend any changes to the registration (RPO, machines, locations of machine


use, etc.) within 30 days of the change.

• Maintain the certificate of registration issued by the applicable regulatory


agency in his/her office or designated radiation files.

G3. Procurement

The following steps are required to purchase / ease any new X-ray producing
machines:

1. The RPO shall be notified of any plans to purchase / lease radiation-producing


machines before the machine(s) is ordered.

2. The RPO shall be provided with or determine / document as part of the purchasing
/ leasing process, all information relating to the proposed procurement, including
the following:

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• The manufacturer,

• Equipment Model,

• Planned use, and

• Scheduled delivery of the machine by the person requesting the purchase /


lease.

G4. Receiving

The RPO shall document receipt of the radiation-producing machine immediately upon
delivery and perform an inspection using the X-ray Machine Inspection Form
(Attachment 6) or equivalent if dictated by a local regulation.

G5. Storage

X-ray machines which must be stored until placed into service shall be stored in a
designated storage area secured to prevent unauthorized removal.

• The X-ray machine shall be locked / tagged out.

G6. Installation

1. The RPO shall be notified by the facility representative when the manufacturer is
scheduled to install (start-up) the machine.

2. No persons shall operate a radiation-producing machine until it has been installed


by the manufacturer’s representative and released to the RPO.

3. The RPO shall survey and inventory the machine as soon as it is available for
operation by personnel using the X-ray Inspection Form (see Attachment 6).

G7. Maintenance / Repair

1. All maintenance / repair activities shall be performed by a factory authorized


representative in accordance with manufacturer’s procedures and/or be performed
by a designated facility representative as authorized by the manufacturer’s
procedures.

2. All maintenance/repair work shall be documented and reviewed with the RPO.

3. Any modification to an X-ray machine is prohibited unless documented


authorization is obtained from the manufacturer or their designated representative.

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G8. Machine Warning Devices and Labelling

1. A readily visible warning light labelled with the words "X-RAY ON" must be
illuminated only when the tube is energized.

• The light must be fail-safe (i.e., failure of the light bulb must shut down the X-
ray machine).

2. Each X-ray machine must be labelled with the following signs bearing the radiation
symbol and the words:

• "CAUTION - HIGH INTENSITY X-RAY BEAM" on the X-ray source housing.

• "CAUTION RADIATION - THIS EQUIPMENT PRODUCES RADIATION WHEN


ENERGIZED" near any switch or keyboard that energizes an X-ray tube.

3. The entrance to each X-ray room or area must be conspicuously posted with a sign
bearing the radiation symbol and the words "CAUTION - X-RAY EQUIPMENT."

4. Each registrant shall post in a place for all workers to read a “Notice to Employees.”

G9. Inspections

1. At intervals not to exceed 12 months, all X-ray machines shall be visually inspected
and inventoried by the RPO or designee.

• Records documenting this visual inspection and inventory shall be maintained


by the registrant for inspection by the regulatory agency.

• The original document shall be maintained by the Q-Chem RPO.

2. Visual inspections shall include verifying the following:

• All labels are legible;

• “Caution X-Ray Equipment” signs are posted at all the entrances; and

• The “X-RAY ON” light is operational.

3. All inspections shall be performed using the X-ray Machine Inspection Form (see
Attachment 6) or equivalent if dictated by a local regulation.

G10. Shipping / Relocation

Written authorization must be obtained from the RPO prior to the shipment offsite or
relocation onsite of an X-ray machine.

• Under no circumstances shall an X-ray machine be shipped without first


obtaining written authorization from the RPO and completing any required
documentation per local regulating agency.

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G11. Special Requirements for X-ray Diffraction Machines [Where Applicable]

The following requirements apply only to the X-ray diffraction machines, since these
machines utilize an open beam configuration:

• A safety interlock is required to prevent any part of an individual's body from


entering into the primary X-ray beam path.

• All unused ports must have a shutter that cannot be opened unless a collimator
or a coupling is connected to the port.

• X-ray Machine Operators shall wear personnel radiation monitoring devices


(whole body and ring) in addition to wearing a dosimeter that measures real-
time exposures and alarms at prescribed exposure levels.

• The operator shall measure X-ray radiation levels and ensure the levels are at
background in the beam path prior to placement of any body part in the path or
vicinity of the beam.

G12. Training

1. Personnel operating an X-ray machine must successfully complete an X-ray


machine safety class which has been approved by the RPO and demonstrate
competence in operating the machine.

2. The X-ray machine safety class shall at a minimum include the following:

• Identification of radiation hazards associated with the use of the radiation


machine;

• Radiation warning and safety devices incorporated into the radiation machine;

• Operating and safety procedures for the radiation machine;

• Symptoms of an acute localized exposure; and,

• Proper procedures for reporting an actual or suspected exposure in excess of


the exposure limits.

G13. Records and Documentation

All records documenting compliance with this procedure must be maintained in the
RPO’s office or a location as designated by the RPP.

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APPENDIX H: INDUSTRIAL RADIOGRAPHY

H1. Description

Industrial radiography is a non-destructive testing method, using gamma or X-ray


radiation, for determining flaws in metal objects. Typical radiography utilizes Iridium-
192 or Cobalt-60 sources (with activities up to 100 Curies) to X-ray pieces of
equipment in various industries. The developed film images are inspected for hidden
cracks, corrosion, erosion, and other flaws in the equipment metal.

Q-Chem typically contracts these types of services involving industrial radiography.


Although the contract radiography company is responsible for job safety involving its
activities, the facility RPO has oversight to ensure that plant personnel and other
contractors are protected as it relates to general radiation safety at the site.

H2. License and Regulations

Q-Chem does not own radiography sources and hence does not have a license for
these materials. However, the RPO must maintain copies of the licenses of all
radiography companies who are approved to work at Q-Chem. sites. Applicable
radiography regulations, including federal, state and local regulations, are to be listed
in the contractual agreement with the company providing radiography services.

H3. Dose Limits and Monitoring

Contract radiography companies shall conduct dosimetry for radiographers. The


maximum dose limit for radiographers is 50 000 µSv/year [50 mSv/yr]. Members of the
general public, i.e., other employees who are not required to work with or monitor
radiation, have a dose limit of 1000 µSv/year [1 mSv/yr].

Exposure monitoring around a radiography job requires knowledge of the source size,
type, location, and collimator. Monitoring shall be performed with a Radiation survey
meter as described in the main text of this document.

H4. Radiography Auditing

A radiography auditing program shall be established at each facility to verify that


contract radiographers are adhering to safe work procedures. This program shall be
part of the Radiation Protection Program and shall be written using the principles
outlined in Operational Excellence Element 2.5, Third-Party Services, to ensure that
exposures to radiation are kept ALARA. Audits shall be conducted by the facility RPO
or his/her designee using Radiography Contractor Onsite Audit Form (see Attachment
9) or equivalent if dictated by a local regulation.

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APPENDIX I: HOW TO DETERMINE ANNUAL RADIATION EXPOSURE

I1. RADIATION WORKERS

An annual radiation exposure calculation is based on a commonly understood and accepted


practice that a radiation worker shall not get closer than one foot for more than five minutes
to operate a shutter on a radioactive device. The one-foot survey result can be used to
confirm that annual radiation exposures are below 500 mR/yr for radiation workers. If this
assumption is not correct, then other measurements must be taken before proceeding with
this calculation.

In determining the annual radiation exposure for radiation workers, the three steps identified
below must be followed to calculate the total number of times a device would have to be
operated in a year to exceed the allowable limit (e.g., 500 mR/yr).

a. Take the one-foot radiation survey in mR/hr.


b. Divide the result from Step (a) by 12 to get mRem for a five-minute time period.
c. Divide 500 mR/yr by the result in Step (b) to get the number of times a device would have
to be operated in a year to exceed 500 mR/yr.

If it is unlikely the actual shutter operation occurrences shall not exceed the calculated
shutter operation occurrences, the licensee is exempt from personnel radiation monitoring.

If the actual shutter operation occurrences do exceed the calculated shutter operate
occurrences, the licensee is not exempt from personnel radiation monitoring and must
monitor each radiation worker that operates the devices.

I2. GENERAL PUBLIC

Determining annual exposure to the general public is based on the commonly understood
practice that a member of the general public would not get closer than one foot when
walking or working by a radioactive device. The one-foot survey result is used to confirm
that general public annual radiation exposures are below 100 mR/yr. If this assumption is
not correct, then other measurements shall be collected before proceeding with the
calculation.

In determining the annual radiation exposure for members of the general public, follow the
two steps below to calculate the total number of hours a member of the general public could
be present and not exceed the allowable limit (e.g., 100 mR/yr).

a. Take the one-foot reading in mR/hr.


b. Divide 100 mR/yr by the result in Step (a) to obtain the number of hours a member of the
general public would have to be present to exceed 100 mR/yr.

The calculated occupancy hours must be less than the actual occupancy time for a member
of the general public. If the actual occupancy time is greater than calculated occupancy
time, then additional restrictions (barricades or signs) must be installed to reduce the actual
occupancy time for members of the general public.

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APPENDIX J: NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM)

J1. Description

Several naturally occurring sources of radiation can result in occupational exposure.


Two examples include radium and radon. Radium is a radioactive solid, while radon is
a radioactive gas. Both are decay products of uranium. Radium can be found in oil
sediments and sludge that can come into contact with the skin. Radon gas decays to
charged solid particles which shall attach to dust in the air and become trapped in the
lungs. Radium, radon, and their decay products are referred to as NORM, or Naturally
Occurring Radioactive Material.

In refineries and petrochemical plants, sludge build-up containing decay products from
the Uranium-238 decay chain may be present. The boiling point of Radon falls
between ethane and propylene and Radon shall be concentrated during distillation in
these streams. As the radon gas travels through various systems, its decay products
(lead and polonium) plate out on equipment. While the equipment is in service, the
radiation risk from these deposits is insignificant; however, precautions must be taken
to avoid skin contact, inhalation, and/or ingestion of the decay products when
equipment is opened for maintenance.

J2. License and Regulations

Certain states regulate NORM as part of their radiological control programs. These
states also grant facilities a general license for NORM when it is discovered at a site.
Some states do not have any regulatory guidance regarding NORM.

• NORM monitoring shall be performed regardless of a lack of regulatory


guidance to determine if any potential occupational exposure exists.

J3. Dose Limits

The following maximum radiation dose limits shall apply:

• Radiation worker: 50 000 µSv/yr [50 mSv/yr].

• Member of the public: 1000 µSv/yr [1 mSv/yr].

• Embryo / foetus in a declared pregnant woman: 5000 µSv for the pregnancy.

J4. General Requirements

1. Before any suspected NORM-contaminated equipment is opened, an external


survey shall be performed to ensure that the equipment does not contain any
residual build-up resulting in elevated gamma radiation readings.

2. Once this equipment is opened, an internal survey shall be performed to verify that
the surface contamination limits are not exceeded.

3. This survey is also to be performed to verify if equipment can be shipped to an


offsite facility for maintenance / repair.

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J5. Instrumentation

1. A Ludlum Model 3 with a Model 44-2 gamma scintillator readout in micro Roentgen
per hour (µR/hr), or equivalent, is required to detect the low levels of gamma
radiation that may be emitted from a piece of equipment.

• This instrument is not capable of detecting alpha or beta radiations.

2. A Ludlum Model 3 (or Bicron Surveyor 50) with a Model 44-9 pancake detector
readout in counts per minute (cpm) or equivalent is required to detect alpha, beta
and gamma radiation that may be emitted from a piece of equipment.

• This instrument is appropriate only for internal surveys.

J6. Surveys

1. When performing external surveys using the gamma scintillator, the following shall
be considered:

• The detector is very fragile.

• The most sensitive part of the detector is the flat front end.

• This instrument picks up background radiation (remember to subtract


background radiation from readings).

• The instrument also picks up radiation from all sources in the area (level
gauges, radiography cameras, etc.).

 Users of the gamma scintillators must know where other radiation sources
are located.

• Readings must be documented in micro Roentgens per hour (µR/hr).

2. These readings are best used to help identify suspect areas of concern.

• The gamma scintillation detector shall pick up the low level gamma rays that
are penetrating the equipment wall.

 When the gamma radiation is present on the outside of the equipment wall,
there is good chance that the alpha and beta radiations are also present on
the inside of this equipment.

3. When performing internal surveys using the pancake detector, the following shall
be considered:

• The Mylar window on this detector is very thin and fragile.

• When using the open window, the detector is detecting alpha, beta, AND
gamma radiations.

• By turning the detector over and using the back side, the detector shall only
detect gamma radiation.

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• The survey meter reads a total contamination in counts per minute (cpm). This
reading must be converted to disintegrations per minute (dpm). Refer to the
instrument manufacturer’s operations manual for performing this conversion.

• This instrument shall also pick up any radiography being performed in the area.

• Readings shall be documented in counts per minute (cpm).

J7. NORM Limits

NORM regulations may vary from state to state. Each facility shall verify with the
agency that regulates radiation any applicable NORM limits. If there are no NORM
limits, use the following:

• Gamma contamination: 50 µR/hr [including background radiation levels]

• Fixed alpha, beta gamma contamination: 5 000 dpm

• Removable alpha, beta gamma contamination: 1 000 dpm

• Removable contamination shall be checked by taking a smear sample inside


the piece of equipment to determine contamination levels

 The smear sample is to cover approximately 100 centimeters

J8. Personal Protective Equipment

Entry into vessels containing NORM, any welding on NORM-contaminated equipment,


or any abrasive work (e.g., scraping, grinding, buffing, polishing, etc.) of NORM-
contaminated equipment requires additional PPE which at a minimum shall include, but
is not limited to, the following:

• Half-face respirator with HEPA cartridges, e.g. P-100;

• Disposable paper suit (e.g., Tyvek®, etc.);

• Gloves (leather or rubber); and,

• Disposable boot covers.

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J9. Shipping of NORM-contaminated Equipment

1. The RPO shall authorize the shipment of any NORM-contaminated equipment


offsite to ensure that the receiver is qualified to accept such equipment.

2. Any NORM-contaminated equipment that is shipped offsite shall be labeled with


appropriate hazard warning.

J10. Decontamination

1. Decontamination is the process of removing NORM from a piece of equipment for


the sole purpose of reducing the level of radiation below established NORM limits.

2. Companies performing NORM-decontamination activities are required to have a


specific license which authorizes the company to perform such activities.

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APPENDIX R: AMENDMENT HISTORY

Rev. Date Amendment Description Reference

1. 01-03-2008 Changes to include Corporate Policy requirements; including the Section 4.13
following:
• Naturally Occurring Radioactive Materials (NORM) assessment
& measurement in process sludges of Ethylene Unit

• Sealed source wipe sampling requirements for devices Appendix F8,


containing radioactive materials. Wipe sampling standard Attachment 10
developed [HSE-SAF-STD-00-0015].
• Radiation Clearance Certificate (RCC) review. “Low-risk” Section 4.14
radiation activities no longer require RCC.
• Update to incident & near miss reporting for radiation-related Section 4.16
issues. Reporting to Corporate RSO now a requirement.
• Two levels of training now provided; General awareness to all Section 4.18
Q-Chem / Baseload and Detailed course for persons who have
to work in Controlled / Supervised Radiation Areas (Where
applicable).
• Inclusion of various audit forms and checklists for various Attachments 6-9
Radiation-related activities / equipment.
2. 01-04-2010 • Normal two year review cycle for procedures. Section 4.12.13
• Only minor change made to procedure as indicated below:
 Changed the medium of communicating radiography
warning announcements. PAGA system no longer used.
All communications shall now be through Q-Chem common
radio channel.
3. 04-07-2011 • Included RLOC plant within scope of the procedure. Section 2
• Updated RPO & Designated RPO details for both Mesaieed & Section 4.4
Ras Laffan sites.
4. 01-07-2012 • Scheduled 12 month review cycle. Ensured procedure meets General.
requirements of EHS-5150 (Gap Analysis conducted). Also
made some minor formatting changes to document, including
company logo.
• Updated JSA meeting requirements. Included topics to be Section 4.11.2
addressed during the JSA meeting.
• Changed the PA announcement requirement before Section 4.11.13
radiography from 30 minutes to 15 minutes. Minor formatting to and Appendix B
the message.
• Program Review Section included. Also included the language Section 4.18
as contained in EHS-5150 on this subject.
• Modified the Radiation Clearance Certificate (RCC) to include Attachment 1
minimum barricade distance. Also made adjustments to the
form to allow electronic input of most data.
• Personal Dose Record Form – made some formatting changes Attachment 2
and logo changes.
• Deleted Attachments 4 and 5 (Surveyor 50 Radiation Standard Attachments
and PEN Dosimeter Standard respectively) from the procedure
(Obsolete).

HSE-SAF-PRO-00-0023 Page 50 of 50

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