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. Very high level of radiation exposure delivered over a short period of time can cause symptoms such as nausea and vomiting within hours and can sometimes result in death over the following days or weeks. This is known as acute radiation syndrome, commonly known as “radiation sickness Exposure to very high levels of radiation, can cause acute health effects such as skin burns and acute radiation syndrome (“radiation sickness"). It can also result in long-term health effects such as cancer and cardiovascular disease.
Exposure to low levels of radiation encountered in the environment does not cause immediate health effects, but is a minor contributor to overall potential cancer risk.
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:
i. Decree Number 31 of 2002: Radiation Protection (Qatar)
ii. Occupational Safety and Health Administrations’ Ionizing Radiation Standard: OSHA 29 CFR 1910.1096
iii. Global OE Procedure EHS-5150, Radiation Safety Procedure
2. SCOPE & PURPOSE
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:
i. Analytical X-Ray Machines, e.g. X-Ray Fluorescence Analyzer
ii. Devices Containing Radioactive Materials:
a) Level/Density Transmitters
b) Gas Chromatogram Analyzer # 5: Electron Capture Detector (ECD)
c) Positive Metal Identification (PMI) Analyzers
iii. Industrial Radiography, e.g. Non Destructive Testing (NDT) work
iv. Naturally Occurring Radioactive Materials (NORM)
3. DEFINITIONS
ALARA (As Low As Reasonably Achievable): It 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.
CBC: Complete Blood Count
CBT: Computer Based Training
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Controlled Radiation Area: 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): 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: 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: The quantity of ionizing radiation absorbed, per unit of mass, by the body or by any portion of the body.
Dosimeter: A device used to determine the external radiation dose a person has received.
DSR: Designated Site Representative
Effective Dose: 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: The dose that takes into account the type of radiation being absorbed by the body tissue. The unit of measurement is Sievert (Sv).
ERP: Emergency Response Plan
Licensed Radioactive Material – Source material, special nuclear material, or by-product material received, possessed, used, transferred, or disposed of under a general or specific license issued by the local regulatory agency
MME: Ministry of Municipality and Environment.
Non-classified Radiation Workers: 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.
NORM: Naturally Occurring Radioactive Materials
Occupational Dose - The dose received by an individual in the course of employment in which the individual's assigned duties involve exposure to radiation or to Radioactive Material from licensed and unlicensed sources of radiation.
Occupational Dose Limit – The maximum level of Ionizing Radiation an individual is permitted to receive during one calendar year from sources in the employer's possession or control.
PPE: Personal Protective equipment
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.
RCC: Radiation Clearance Certificate _ A document issued by the radiation protection officer (RPO) to an end-user authorizing the use of, or work on, a specific radioactive source on the facility.
Radioactive Material: Any material which emits, by spontaneous nuclear disintegration, alpha or beta particles; gamma rays or neutrons.
RPO: Radiation Protection Officer - Qualified technician designated by the competent agency, or employed in the corporation which uses radioactive sources in order to oversee
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the implementation of the prescribed radiation protection regulations and give advice on radiation protection.
Q-Chem Radiation Protection Officer(s) – The Industrial Hygiene Specialists or Designee from Q-Chem and RLOC Facilities as detailed in section 4.4.
RSM: Radiation Safety Manual
Sealed Source: 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: 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: An area accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 50µSv (0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates.
TLD: Thermoluminescent Dosimeter
4. PROCEDURES
4.1. General Safety Precautions
i. All work involving sealed radioactive sources shall be carried out in accordance with a Permit-To-Work (PTW) and Radiation Clearance Certificate (RCC) system.
4.2. Radioactive Sources
i. A list of all radioactive sources used at Q-Chem is maintained by the Q-Chem RPO.
a) Attachment 3: Radiation Source List – Mesaieed Complex (HSE-SAF-LST-00-0012).
b) Innov-X System Alpha 2000 XRF Analyzer, Serial Number 9567 – Ras Laffan Complex
c) Olympus, DPO-2000-CC XRF Analyzer, Serial Number 540534 – Ras Laffan Complex
4.3. Procurement of Radioactive Sources/Equipment
i. The following steps shall be followed to purchase any devices/equipment containing radioactive material:
a) The site RPO shall be notified of any plans to purchase a device/equipment before initiating the purchase.
The end user or person requiring the purchase of the device/equipment shall initiate this process.
NOTE 1
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/her absence if required.
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Notification shall be done using Attachment 8: Procurement of Radioactive Source/ Equipment Form – HSE-SAF-SFM-00-0141.
The RPO notification shall include the device manufacturer, model number, isotope, activity, and intended use.
b) The RPO shall initiate all license amendments to add radioactive materials.
Applying or amending a specific license may take several months.
c) The end-user shall initiate Management of Change (MOC) requirements when devices containing radioactive materials are installed, relocated, or removed from service within the facility.
d) Using SAP System, the end user shall create a manual PR when there is a need for radioactive material by removing the block for procurement in the material master. The blocking/unblocking is controlled by Industrial Hygiene (IH) Section.
e) IH authorized person shall review the PR created by end user for all technical information and documents attachments, and only then, remove the block in the material master to allow Procurement Section to process once PR is released.
4.4. Radiation Protection Officer
i. The Q-Chem Radiation Protection Officer (RPO) shall oversee radiation safety matters on site.
a) Mesaieed Complex
The Industrial Hygiene Specialist is the appointed Radiation Protection Officer (RPO).
The Industrial Hygiene Safety Technician/Developee shall be appointed as the designated RPO in the absence of the Industrial Hygiene Specialist/RPO.
b) Ras Laffan Complex
The Industrial Hygiene Specialist is the appointed Radiation Protection Officer (RPO).
The Safety Specialist shall be appointed as the designated RPO in the absence of the Industrial Hygiene Specialist/RPO.
ii. These delegations shall be documented and retained on file for review.
iii. The RPO shall have the following minimum qualifications:
a) Specialized Training approved by the Ministry of Municipality and Environment (MME) on Radiation Safety.
b) Passed the RPO written exam conducted by the MME.
c) Be a fulltime Q-Chem employee.
4.5. Permissible Exposure Limits
i. Exposure to ionizing radiation shall be kept As Low As Reasonably Achievable (ALARA).
ii. Radiation exposure limits shall only be applicable to occupational exposure.
iii. Exposures received from diagnostic, therapeutic, X-Ray machines for medical treatment and background radiation, shall not be included in any of these exposure limits:
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4.6. Personnel Monitoring
Personnel monitoring is the measurement of radiation doses to persons in order to ensure control of exposure to radiation.
i. TLD or Film badges shall be required for each Classified Radiation Worker where applicable.
ii. The TLD/Film badges shall be worn by Classified Workers at all times when working with or handling radioactive materials.
a) The badge shall only be worn by the individual to whom it was issued.
b) The badge shall be worn on the body on outer clothing.
c) Badges shall only be worn at work; i.e. they are for assessing occupational exposure.
d) Badges shall not be worn during medical exposures, e.g. X-Rays.
iii. The TLD/Film badge shall be stored in a radiation-free area whenever it is not in use.
iv. The badge shall not be left or stored in a highly humid environment, in high temperatures or inside a vehicle.
v. TLD/Film badges (when used) shall be returned to the Radiation Protection Officer when requested.
4.6.2. Electronic Radiation Dosimeter (Bleepers)
i. Where applicable, all personnel entering and/or performing work that may expose them directly or indirectly with a radioactive source shall be supplied with a battery operated electronic dosimeter (Bleeper).
a) The dosimeters are not a substitute for TLD/Film badges that may be issued to employees (Classified Radiation Workers).
b) They shall be worn in conjunction with TLD/Film badges (for Classified Radiation Workers only).
c) They are not a substitute for suitable calibrated dose-rate monitors.
ii. Electronic dosimeters shall have a minimum measuring range of 0-200mR (0-2mSv).
iii. The electronic dosimeter shall be reset to zero dose before the start of each radiation job.
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 & extremities) 500mSv / annum
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iv. Each individual shall enter the dose received in the daily dose record after completion of the job (see Attachment 2).
v. 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.
a) The job shall not be resumed until the defective dosimeter is replaced.
b) The TLD badges (where used) of employees involved in the work shall be processed as soon as possible.
c) The results (as applicable) shall be analyzed by the RPO before allowing personnel to resume work.
vi. 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:
a) The results shall be communicated to the affected employees.
b) The incident shall be investigated.
c) The individuals involved shall be assigned to non-radiation work.
vii. If the dose received is within limits, individuals can be allowed to resume normal duties.
4.6.3. Medical Screening and Surveillance
i. Affected persons shall undergo medical screening and surveillance as below:
a) Pre-assignment [Where Applicable]
On joining Q-Chem or transferring to the role of Q-Chem Classified Radiation Worker.
b) Periodic [Where Applicable]
Annually for Q-Chem Classified Radiation Workers.
c) 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.
d) 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:
o Fitness for duty
o Chest X-Rays
o Complete Blood Count (CBC)
ii. Employee medical reports shall be maintained as per the Q-Chem Access to Employee Exposure and Medical Records Policy (AD-MED-PCY-00-0001).
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4.8 Radiation Survey Meters
i. 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:
a) 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).
b) 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.
c) 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.
4.9 Signage and Demarcation
i. Each Supervised Radiation Area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol (Stock Item - MM: 506393) (Appendix E) and the words:
CAUTION
SUPERVISED RADIATION AREA
ii. 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
iii. 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
iv. 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
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4.10 Storage of Radioactive Sources
i. The owner of the radioactive sources (Q-Chem/Contractor) shall be responsible for the safe storage of all radioactive sources under his/her ownership.
ii. The following conditions shall apply during the storage of radioactive sources not in use:
a) The shutter of the radioactive source shall be in closed position.
b) 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.
c) No flammable, combustible or explosive material shall be kept near or inside the storage area.
d) The storage area shall be designed such that the dose rate on the outer surface does not exceed 1µSv/hr.
e) 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.
f) The store shall be monitored regularly by the relevant Radiation Protection Officer and monitoring records shall be kept.
g) 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.
A copy of this register shall be forwarded to the Q-Chem RPO. The register should include the following:
o Identification of the source
o The date of receipt on site
o The nature of radioactive substance
o The activity of radioactive substance
o The location of the radioactive substance
o The date the radioactive substance is taken off site
h) 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.
4.7. Transportation of Radioactive Sources
i. A properly equipped and marked vehicle shall be used to transport shielded equipment containing radioactive sources.
NOTE 2
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.
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a) General public and personal vehicles carrying passengers shall not be used to carry radioactive sources.
b) The vehicle shall be equipped with a suitable storage container in which the radioactive package shall be placed during transport by road.
ii. The transport vehicle shall be clearly marked with the following signage:
a) Radiation warning symbol (vehicle placard) as illustrated in Appendix C
b) 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
iii. The source container shall be marked with the radiation caution warning symbol (Appendix E).
iv. The following basic requirements shall be adhered to when transporting radioactive materials into QP Premises (Industrial Cities):
a) MME Vehicle License to transport radioactive materials
b) Valid MME Radiation Worker License of the company
c) Storage container labelled and secured with padlock
d) Radiation Harzard Warning signs shall be posted on both vehicle and container
e) Radiation survey meter shall be available with the company
v. Avoid transporting radioactive materials into the QP Premises during the following hours:
a) Peak periods: 06:00 to 08:00hrs
b) Shift change: 14:00hrs
vi. The relevant RPO is responsible for accompanying a radioactive source when it is transported by road:
a) To or from the Q-Chem Site
b) At all times while on the Q-Chem site (unless locked away as stated in Section 4.12.(ix))
vii. 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:
a) The documentation to ensure the correct source has been delivered.
b) The source container for any damage.
c) Ensure the Identification tag is attached to the source container.
d) 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
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e) Complete a Radioactive Shipment/Receiving Form (Attachment 6) on the same shift or day the shipment arrives on site.
4.8. Radiation Clearance Certificate
i. A Radiation Clearance Certificate (RCC) shall be obtained prior to any maintenance work that may expose personnel directly with a radioactive source. Such tasks may include, but are not limited to the following:
a) Removing/replacing the shutter/rotor
b) Removing/replacing or drilling on the shutter closing mechanism / lever
c) Removing any outer components that normally conceal the source / source holder
d) Vessel Entry into equipment that has a device containing a radioactive source
e) Maintenance on XRF analyzer
f) Isotope injection for leak identification
ii. A RCC is not required for maintenance-related tasks where the sealed radioactive source is not directly 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:
a) Shutter closing/opening as part of normal Lock Tag & Try (LT&T) procedures
b) Calibration or troubleshooting of nuclear gauge control instrumentation
c) Planned Maintenance (PM) on the outer surface of the gauge, e.g. cleaning or applying lubricants for the shutter closing mechanisms
iii. The following procedure shall be followed for obtaining a Radiation Clearance Certificate (RCC):
a) The RCC shall be obtained from the site (Q-Chem/RLOC) RPO.
b) The site RPO shall be notified of such planned work activities at least 24-hours in advance.
The Q-Chem/RLOC site representative shall notify the site RPO
Notification can be through email or telephone
The site RPO will indicate an appropriate time to meet for the RCC approval process
c) The individual who will perform the radiation work (Contractor RPO, Service Engineer or Vendor) shall report to the site RPO together with the DSR/Designate to obtain the RCC.
NOTE 3
Contact the Q-Chem RPO/Designate for tasks not listed in this Document.
NOTE 4
Contact the Q-Chem RPO/Designate for tasks not listed in this document.
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d) The following documents/instrumentation shall be required during the RCC approval (see following slides for examples):
The Contractor’s Radiation Safety Manual (for Radiography)
o Updated/Revised RSM’s shall be forwarded to Q-Chem RPO when available
o Companies those 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.
Certifications and/or Radiation Licenses (MME) of the affected radiation workers
Radiation Survey Meters (Minimum of 2)
Personal Electronic Dosimeters/Bleepers
Monitoring Badges (TLD Badges)
Radiation Emergency Equipment
Warning signage & Barricades
iv. No radiation clearance certificate shall be issued if there is no RPO to supervise the operation.
a) The Contractor RPO shall be physically present at worksite for all Industrial Radiography.
b) Q-Chem RPO/Designate shall be contactable /reachable for all Q-Chem radiation jobs where a radiation clearance certificate is required.
v. Work Permitting (PTW issuing) for Radiation Work.
a) All radiation work shall be conducted through a work permit system.
b) The permit receiver (together with the contractor RPO for Radiography jobs) shall present the RCC to the permit issuer for review during the permitting process.
c) The permit issuer shall review, verify and confirm all the requirements/documents specified in the RCC before issuing the permit.
d) An approved JSA for that “specific job” shall be available and attached to the RCC.
e) The work permit shall not be issued unless ALL conditions stated on the RCC/JSA are fully adhered to / compliant at the time of issuing.
f) 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
NOTE 5
Passive monitoring dosimeters (e.g. PEN Dosimeters) shall no longer be accepted for Radiography jobs.
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vi. Radiation Clearance Certificate (RCC) Validity.
a) 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.
vii. Job Completion and RCC Closure
a) 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.
b) The RCC shall be removed from the field.
c) 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.
d) The DSR/Designate shall return 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)
Any Q-Chem monitoring devices issued at start of task
e) The Q-Chem RPO shall retain the closed out RCC for a minimum period of one (1) calendar year.
4.9. Industrial Radiography
i. 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.
ii. A Permit To Work (PTW) shall only be initiated upon the completion of the following:
a) Radiation clearance (by obtaining Radiation Clearance Certificate) from Q-Chem RPO / Designate.
NOTE 6
The work permit shall be suspended IMMEDIATELY if any of the conditions listed on the RCC/JSA change during the execution of work.
NOTE 7
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.
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b) 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
Radio communication to “All Site Personnel” about the execution of radiography work via the common radio channel (Mesaieed: 998 and RLOC: Broadcast Channel)
Notifications that shall be conducted 15 minutes before the start of work and at the end of radiography work.
iii. The following are the minimum required personnel for the JSA:
a) Permit Issuer; or
b) Area operator for production areas (where applicable);
c) Safety Representative or Fire Safety Coordinator;
d) The contractor’s Radiation Protection Officer (and Radiographers if possible) who shall be involved with the job.
iv. The Contractor’s Emergency Response Plan (ERP) shall be presented at the JSA meeting for all Industrial Radiography work.
a) The JSA shall not be concluded and signed off without the Emergency Response Plan.
v. 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.
a) 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.
b) 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.
vi. The contractor RPO shall be present at all times at the worksite when the work is being carried out.
a) The RPO shall manage the Controlled Radiation Area at all times while radiography is in progress.
b) The work shall be carried out by a minimum of two Classified Radiation Workers / Radiographers (excluding the RPO).
vii. A “Controlled Radiation Area” shall be established for all Industrial Radiography operations.
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a) 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.
b) The Controlled Radiation Area shall be surrounded by substantial barriers, barricade tape or clearly visible ropes/ribbons marked with ‘Danger Radiation – Keep Out’ placards for the safety of the Non-Classified persons, thereby prohibiting their entry.
c) The Radiation Hazard Warning signs shall be in Arabic and English.
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 at all times during radiography.
The position of the barriers may be altered after exposure, subject to monitoring radiation levels (using a calibrated survey meter).
d) It is the duty of the Contractor RPO to patrol/supervise the area and warn Non-Classified persons from coming near this outer cordon.
viii. Whenever possible during radiography, the radiographer shall use collimators to reduce the area affected by radiation.
a) The collimator shall be firmly supported.
ix. The exposure container shall not be left unattended at any time during radiography.
a) The exposure container/cameras shall be locked away in the appropriate storage container on the transport vehicle.
b) The Radiographer (Contractor RPO) shall keep the key of the locking device until radiographic operations recommence.
x. Upon completion of the radiographic operations, the exposure container / camera shall be locked and stored.
xi. Monitoring shall be carried out to ensure the safe return of the source to its container.
xii. All radiographic work shall be suspended if any part of the equipment is noticed to have become defective or damaged during radiographic operations.
a) Work shall remain suspended until the equipment is replaced or repaired to a safe operational condition.
xiii. Prior to the commencement of radiation work, the following steps shall be taken:
NOTE 8
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.
NOTE 9
No radiation work shall be permitted on the Q-Chem premises without a valid radiation survey meter being present. See Section 4.7 for survey meter specifications.
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a) 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.
b) The DSR / Designee shall ensure adequate representation on the JSA team.
c) 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.
d) Safe barrier distances shall take into account all working levels around radiographic work.
e) The Announcement of radiography work (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.
f) 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.
g) 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.
h) 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/her possession.
CAUTION
Under no circumstances shall any person other than the classified radiation workers cross the safety barrier during radiographic operations.
4.10. Density/Level Transmitters
i. The gamma gauges are located in the Polyethylene Reactor Structures, i.e. Trains 1, 2 and 3 (see Attachment 3):
a) 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)
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b) 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)
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)
ii. These instruments are intended to remain in service for the lifetime of the Plant.
a) Routine maintenance of the receiver and calibration shall be done on site in accordance with manufactures recommendations.
b) If it becomes necessary to overhaul or replace the instrument it shall remain sealed and shall be returned to the manufacturer for remedial work.
c) This work shall be done under the instruction and supervision of manufacturer’s representative who shall be designated as the Radiation Protection Officer.
iii. 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.
iv. The following two methods shall be utilized to confirm that the device shutter is closed properly:
a) Process control instrumentation (reading on DCS) shall be checked to ensure that the readings from the radioactive source have decreased to zero.
b) 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.
v. Once the shutter is in the OFF position it shall be locked.
a) Normal Lockout, Tag out and Try (LT&T) procedures shall be followed.
b) 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.
i. Quantitative measurements (by Q-Chem RPO/Designate) for radioactivity shall be conducted on equipment anticipated to potentially be contaminated/contain NORM when such equipment is opened for maintenance. Such equipment may include but is not limited to the following:
a) Mesaieed Complex
AGRU – Metering Skid Motor Operated Valve [S/N: 1098150]/ CO2 Absorber Outlet [08-95-103]
iii. When the equipment suspected of containing NORM is opened or disassembled, care is needed to preclude radioactive particles from being inhaled or ingested.
a) Any levels of gamma radiation exceeding 0.05mR/hr or greater than 1000 dpm shall be identified with signs indicating radioactive material.
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b) All other NORM containing equipment shall be posted/labelled as containing NORM.
iv. This survey shall also be performed to verify if equipment can be shipped to an offsite facility for maintenance/repair.
v. An appropriate NORM Control Program shall be developed if radiation levels exceed prescribed limits (see Appendix J).
vi. 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:
a) Half-face respirator with HEPA cartridges, e.g. P-100
b) Disposable paper coverall
c) Disposable boot covers or Rubber Boots
d) Safety glasses
e) Neoprene rubber gloves [If leather gloves are used, e.g. due to requirements of task, they must be disposed of after use)
f) Not required if the NORM is not removable and no maintenance activities shall cause the NORM to become airborne. These are activities such as, cutting, grinding, buffing, machining, chiselling or drilling
vii. Employees working on contaminated equipment shall not eat, smoke, and drink, etc. while engaged in such activities.
viii. Skin contact shall be avoided with interior surfaces where practicable.
ix. 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:
a) Washing shall be complete to the point where no evidence of material is present, i.e., no evidence of discoloration on skin
b) This shall take 1.5 to 2 minutes
x. 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.
xi. Items such as hard hats, safety glasses, chemical goggles and respirators shall be placed in plastic bags, sealed and tested by the Q-Chem RPO/Designate for NORM before being released from the job site for further use or decontamination.
a) Items found to be contaminated with NORM above acceptable levels shall be disposed of as NORM waste.
xii. Every effort shall be made in the preparation of NORM 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).
xiii. 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.
a) Items removed from contaminated equipment shall not be placed in a scrap metal or trash dumpster without a radiation survey by the RPO / Designate.
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4.12. Emergency Response
i. All users of radioactive materials shall be familiar with the Emergency Action and Accountability Procedure (HSE-ERT-PRO-00-0030) before any emergency arises.
ii. Refer to Appendix A for Q-Chem Emergency Contact Details for dealing with radioactive materials.
a) 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 Safety Coordinator (Incident Commander) shall have overall functional/strategic control of the incident on the Q-Chem site.
iii. If a gas detector alarms or the Plant alarm sounds at any time during the job:
a) The PTW and RCC is cancelled.
b) Work shall be stopped immediately.
c) Equipment shall be turned off and secured as quickly as possible.
d) Personnel shall leave the area proceeding to nearest assembly point.
e) The contractor RPO or Lead worker shall notify the Permit Issuer.
4.13. Incident and Near Miss Reporting
i. The Q-Chem “Event Reporting Procedure (HSE-SAF-PRO-00-0001)” shall be followed in reporting and investigating an incident (or near miss) involving radioactive materials.
ii. The Q-Chem RPO or designate shall be notified promptly of all accidents, incidents, or near misses involving the following scenarios:
a) Possible, personnel overexposure to radiation
b) Possible personnel or area contamination with radiation
c) Failure (s) or malfunctioning of any radiation equipment safety devices
d) Detachment / loss of a radioactive source
iii. 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 Municipality and Environment (MME).
iv. 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:
NOTE 10
The levels of NORM found in process equipment can vary with feedstock; 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 NORM.
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a) Exposure of the whole body of any individual to 25rems [0.25Sv / 250mSv] or more of radiation;
b) Exposure of the skin of the whole body of any individual to 150rems [1.5Sv / 1500mSv] or more of radiation;
c) Exposure of the feet, ankles, hands, or forearms of any individual to 375rems [3.75Sv / 3750mSv] or more of radiation; OR
d) 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.
v. 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:
a) Exposure of the whole body of any individual to 5rems [0.05Sv / 50mSv] or more of radiation;
b) Exposure of the skin of the whole body of any individual to 30rems [0.3Sv / 300mSv] or more of radiation;
c) Exposure of the feet, ankles, hands, or forearms to 75rems [0.75Sv / 750mSv] or more of radiation; OR
d) "Reports of overexposure and excessive levels and concentrations."
vi. 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."
4.14. Record Keeping
i. All records documenting compliance with this Procedure shall be kept in the Q-Chem IH office or as indicated in the applicable sections of this Procedure.
ii. Where applicable; a list of all Classified Radiation Workers shall be maintained by the Q-Chem RPO.
iii. Records of the results of surveys and personnel (where applicable) radiation exposure monitoring shall be maintained for the life of the facility.
iv. Radiation survey meter calibration and maintenance records shall be available on request from the Q-Chem RPO.
a) The applicable contractor’s RPO is responsible for updating and maintaining their records and making them available to Q-Chem RPO when so required.
v. Records of all Radiation Clearance Certificates (RCC) shall be maintained by the Q-Chem RPO for duration as per the Q-Chem/RLOC Records and Information Retention Schedules (QC-IMT-SHD-00-0001/RC-IMT-SHD-00-0001).
4.15. Training
i. No individual shall use radiation producing equipment or work with radioisotopes without training.
ii. 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.
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iii. 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:
a) Storage, transfer, or use of radiation sources/equipment;
b) Health risks and symptoms associated with exposure to radiation sources / equipment;
c) Precautions or procedures to minimize exposure;
d) Purposes and functions of protective devices employed;
e) Controls that workers may employ to minimize radiation exposure;
f) The applicable provisions of regulations and licenses for the protection of personnel from exposure to radiation sources / equipment;
g) 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;
h) The appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation sources/equipment; and
i) The radiation exposure reports which workers may request.
iv. 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.
v. The general Q-Chem population/Baseload Contractors shall receive a Radiation General Awareness Course annually.
a) The content of this training course shall be determined by the Q-Chem RPO.
vi. All training required by this procedure shall be documented.
4.16. Program Review
i. Radiation program reviews shall be conducted at least annually, with time between reviews not to exceed twelve months.
ii. The program reviews shall be conducted by the site RPO’s using the Radiation Procedure Annual Review Checklist (HSE-SAF-SFM-00-0108).
iii. The following items shall be addressed during the review process:
a) Records of any incidents or near misses involving Ionizing Radiation exposure.
b) Lesson learned reports from other CPChem affiliate facilities.
c) Any audit findings from the previous twelve month period.
d) Legislation changes, including changes to the Global OE procedure EHS-5150, Radiation Safety.
e) New work practices or work locations (if any) involving potential exposure to Ionizing Radiation sources.
f) Review of the Radiation Protection training modules.
iv. The Radiation Protection Procedure (HSE-SAF-PRO-00-0023) shall be reviewed and revised under the following conditions:
a) Every two (2) years, with time between reviews not to exceed twenty-four months.
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b) If required by the outcomes of the annual program reviews.
5. RESPONSIBILTIES
5.1. Q-Chem Radiation Protection Officer
i. Prepare the Radiation Protection Procedure and facilitate its review.
ii. Assign RPO responsibilities to suitable designate in his/her absence.
iii. Authorize radiation clearance certificates for all radiation work at Q-Chem.
iv. Conduct radiation surveys, audits and sealed source wipe tests where required.
v. Manage and monitor the usage and interpretation of electronic radiation dosimeters used by Q-Chem employees.
vi. Inspect and clear all items arriving/received at the Q-Chem site that contain radioactive materials.
vii. Advise Q-Chem on radiation safety matters.
viii. Report on radiation safety incidents to the MME and the Corporate RSO within the Corporate EHS organization.
ix. Develop and provide Radiation Safety Training to affected end users.
x. Ensure contractor radiography service providers used on site are made familiar with the requirements of the Q-Chem Radiation Protection Procedure.
xi. Maintain all records pertaining to radiation monitoring.
5.2. Designated Site Representative (DSR) or Designee/Area Supervisor
i. Ensure a copy of this Procedure is presented to the radiography contractor prior to the JSA meeting.
ii. Ensure adequate notice is given to affected stakeholders regarding any Industrial Radiography scheduled for the Q-Chem site.
iii. Inform the Q-Chem RPO/Designate regarding the expected arrival of any radioactive materials at the Q-Chem premises.
iv. This includes contractor radiography service providers arriving on the Q-Chem site with radio-isotopes/X-ray sets.
v. Ensure the JSA has been completed before the issuance of a PTW.
a) Ensure there is an adequate representation on the JSA team.
b) Ensure contractor radiography service provider has all the necessary documentation before arrival on the Q-Chem site for Radiation Clearance Certificate & JSA meeting.
c) Ensure the JSA is communicated during the toolbox talk to the affected employees.
5.3. Contractors/Radiography Service Providers
i. Meet all procedural and documentation requirements as per the radiation protection procedure.
ii. Meet all requirements as stated on the Radiation Clearance Certificate (RCC).
i. Be familiar with all emergency response procedures related to radiation safety at Q-Chem.
ii. Ensure they have received radiation safety training before working with radioactive materials/equipment.
iii. Wear an electronic radiation dosimeter (where applicable) at all times when entering or working in a designated radiation area.
a) Controlled Radiation Area
Entering a vessel fitted with a density or level transmitter.
Entering the demarcated boundary during Industrial Radiography.
b) Supervised Radiation Area
During all RCC-required radiation tasks (as listed in Section 4.13 within the demarcated areas around vessels at the PE Reactor structures.
iv. Report any incidents or near misses involving radioactive materials:
a) Immediately to the Q-Chem RPO/Designate.
b) Follow the Q-Chem “Event Reporting Procedure (HSE-SAF-PRO-00-0001)”.
v. Follow the requirements of this procedure as applicable to them.
5.5. Radioactive Material Owners
i. Ensure proper storage (where applicable) and maintenance of all equipment & instruments containing radioactive sources.
ii. Ensure all radiation-containing sources/equipment is clearly identified with suitable hazard warning signs.
a) Keep a local register of all radiation-containing sources/equipment.
b) Forward all such records and updates to the Q-Chem RPO.
iii. Provide training on the safe use of equipment/instruments containing radioactive materials to all employees required to use such instruments / equipment.
iv. Ensure all radiation safety signage/labelling requirements are fulfilled within their affected areas.
v. Complete a Radioactive Shipment/Receiving Form (Attachment 6) before shipping or receiving any radioactive source-containing equipment.
vi. Consult with the Q-Chem RPO/Designate when necessary or if requiring clarification on matters pertaining to radiation safety.
vii. Notify the site RPO of any plans to purchase a device before initiating the purchase requisition.
viii. Create a manual PR when there is need for radioactive material by removing the block for procurement in the material master.
5.6. Fire Safety Coordinator (FSC)
i. Oversee the overall site Emergency Response Plan.
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ii. Liaise with the contractor RPO during any emergency situations that may arise during industrial radiography work on the Q-Chem premises.
5.7. Health Services
i. Where applicable; schedule and conduct medical screening and surveillance for Q-Chem Classified Radiation Workers and anyone requiring surveillance in an emergency situation.
ii. Maintain all employee medical records as per Q-Chem’s Access to Employee Exposure and Medical Records Policy (AD-MED-PCY-00-0001).
5.8. Materials Warehouse
i. Contact the Q-Chem RPO/Designate when receiving any items containing radioactive materials.
5.9. Technical Training
i. Ensure the Radiation Protection Procedure (CBT) is assigned to users.
6. REFERENCES
6.1. Decree Number 31 of 2002: Radiation Protection: Ministry of Environment (MoE), Qatar.
6.2. Title 29 of the Code of Federal Regulations, Section 1910.1096, Ionizing Radiation (OSHA).
6.3. US Nuclear Regulatory Commission Regulations Title 10 of the Code of Federal Regulations, Part 20, Standards For Protection Against Radiation: Appendix C.
6.4. Chevron Philips’ Corporate Radiation Safety Procedure: Document Number EHS-5150.
7.10. Attachment 10 – Radiation Protection Program Training (HSE-SAF-CBT-00-0060)
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8. APPENDICES
8.1. Appendix A – Contact Details for Radiation Sources
8.2. Appendix B – Radiography Announcement (Common Radio Channel)
8.3. Appendix C – Vehicle Placard (Warning Sign)
8.4. Appendix D – Radioactive Source Notice (Transport Vehicles)
8.5. Appendix E – Radiation Caution Symbol (Trefoil)
8.6. Appendix F – Devices Containing Radioactive Material
8.7. Appendix G – Analytical X-Ray Machines
8.8. Appendix H – Industrial Radiography
8.9. Appendix I – How To Determine Annual Radiation Exposure
8.10. Appendix J – Naturally Occurring Radioactive Material (NORM)
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8.1. APPENDIX A
Q-CHEM CONTACT DETAILS FOR RADIATION SOURCES
MESAIEED SITE
Radiation Protection Officer (RPO) Sara Khamis Industrial Hygiene Specialist Safety Department Qatar Chemical Company Ltd. Tel: 4476-7320 (Office) Mobile: 66680744
Designated Radiation Protection Officer (RPO) Ferdinand L Santos /IH Technician Safety Department Qatar Chemical Company Ltd. Tel: 4476-7352 (Office) Mobile: 55311757
Quality Control Laboratory Laboratory Superintendent Technical Department Qatar Chemical Company Ltd. Tel: 4476 7145 (Office)
Equipment Reliability Group Equipment Reliability Superintendent Technical Department Qatar Chemical Company Ltd. Tel: 4476 7060 (Office)
Polyethylene Units Unit Superintendents Production Qatar Chemical Company Ltd. Tel: 4476 7122 (Office) Tel: 4409 3100 (Office)
Materials Warehouse Head, Materials Warehouse Qatar Chemical Company Ltd. Tel: 4457 2465 (Office)
Safety Department Safety Manager Safety Department Qatar Chemical Company Ltd. Tel: 4476 7326 (Office)
RAS LAFFAN SITE
Radiation Protection Officer (RPO) Amit Parikh Industrial Hygiene Specialist HSE Department Ras Laffan Olefins Company (RLOC). Tel: 4457-2396 (Office) Mobile: 335-16-467
Designated Radiation Protection Officer (RPO) Abdul W Sheikh Safety Specialist HSE Department Ras Laffan Olefins Company (RLOC). Tel: 4457-2390 (Office) Mobile: 338-93-466
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8.2. APPENDIX B
RADIOGRAPHY ANNOUNCEMENT (COMMON RADIO CHANNEL)
NOTE: The following announcement through the Common Radio Channel SHALL be made 15 minutes before the scheduled Radiography begins.
ATTENTION – THIS IS A RADIOGRAPHY ANNOUNCEMENT
[REPEAT TWICE MESSAGE BELOW]
NOTE: The following announcement through the Common Radio Channel SHALL be made when Radiography is completed.
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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8.5. APPENDIX E
RADIOACTIVE SOURCE NOTICE (TRANSPORT VEHICLES)
This symbol must be printed in COLOR when used.
Material Master No. MM: 506393
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8.6. APPENDIX F
DEVICES CONTAINING RADIOACTIVE MATERIAL
1. Description
i. 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.
ii. Portable devices containing sealed sources of radioactive material are also typically used in Positive Material Identification (PMI) programs.
2. Licensing
Radioactive material devices can be licensed as either “specifically licensed” or “generally licensed.” The two license categories are further described below:
i. Specific License
a) 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.
b) 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.
ii. General License
a) 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.
b) 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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3. Procurement
The following steps are required to purchase a device containing radioactive material:
i. The site RPO must be notified of any plans to purchase a device before initiating the purchase.
a) The RPO notification must include the device manufacturer, model number, isotope, activity, and intended use.
ii. The RPO shall initiate all license amendments to add radioactive materials. Applying or amending a specific license may take several months.
a) The RPO shall notify the Material Warehouse if item is approved.
iii. 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.
4. Receiving Radioactive Material
i. The RPO or designee must survey, perform a leak test on each device, and complete a Radioactive Shipment/Receiving Form (Attachment 6) or equivalent if dictated by a local regulation, on the same shift or day the shipment arrives at the licensee’s site.
5. Temporary Storage of Devices Containing Radioactive Material
i. 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).
6. Installation of Devices Containing Radioactive Material
i. 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.
7. Semi-Annual Inspections
i. At intervals not to exceed six months, each device containing radioactive material shall be visually inspected and inventoried.
ii. Records documenting the visual inspection and inventory shall be maintained by the licensee for inspection by the regulatory agency.
Visual inspection shall include verification of the following:
a) The source label is legible,
b) The source has a “Caution Radioactive Material” sign,
c) The device is mounted correctly, and
d) The on/off shutter mechanism functions properly.
iii. All inspections shall be completely documented using Radioactive Source Inventory and Maintenance Inspection Form (Attachment 5) or equivalent if dictated by a local regulation.
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8. Sealed Source Wipe Tests
i. Sealed source wipe tests shall be performed per the device registry (Attachment 3 ) Radiation Source List for details) for each device containing radioactive material.
ii. The registry can be obtained from the manufacturer, to determine the interval for performing sealed source wipe tests.
iii. The wipe of a sealed source shall be performed using a wipe test kit or method [see “Sealed Source Wipe Sampling Standard” HSE-SAF-STD-00-0015] approved by the licensing agency or authority having jurisdiction.
iv. The wipe sample shall be taken from the nearest accessible point to the sealed source where contamination might accumulate.
v. The wipe sample shall be analyzed for radioactive contamination.
vi. 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
vii. Sealed source wipe test kits shall be obtained from and analyzed by Suntrac Services, Inc. or an equivalent vendor approved by the Corporate RSO
9. Vessel Entry
i. 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.
ii. 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.
a) 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.
iii. The following two methods shall be utilized to confirm that the device shutter is closed properly:
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.
10. Removal of Devices Containing Radioactive Material
i. If the licensee is authorized to remove devices containing radioactive material, the removal procedures submitted to the licensing agency shall be followed.
ii. If the licensee does not have procedures for removing devices containing radioactive material, the device shall NOT be removed.
iii. A licensed third party contractor shall be contacted to perform the removal process using authorized procedures.
11. Storage of Devices Containing Radioactive Material
i. 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.
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ii. Each storage location shall have a “CAUTION RADIOACTIVE MATERIALS” sign to communicate that radioactive material is present.
iii. This area and all sources kept within shall be included in the documented semi-annual inspection.
12. Shipping Devices Containing Radioactive Material
i. 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.
ii. The shipment must be packaged, labelled, and have all paperwork completed in accordance with all applicable local regulations.
iii. The RPO must survey the shipment and complete the Radioactive Shipment / Receiving Form (Attachment 6) or equivalent if dictated by a local regulation.
iv. The shipping form should accompany other required shipping papers such as the Bill-of-Lading (BOL) containing the proper regulatory shipping description.
v. The licensee must receive a letter of transfer from the company receiving and possessing the radioactive material.
13. Radiation Worker Annual Radiation Exposure
i. The maximum exposure limit for a Radiation Worker is 50 000 µSv/yr [50 mSv/yr].
ii. Each licensee is required to document each radiation worker’s exposure if the worker is issued a personnel radiation badge.
iii. 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).
iv. If a radiation worker declares her pregnancy to the RPO, the exposure limit is 5000 µSv for the term of the pregnancy.
14. Members of the General Public Radiation Exposure
i. 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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8.7. APPENDIX G - ANALYTICAL X-RAY MACHINES
1. Description
i. 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:
a) 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.
b) 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.
2. Registration
i. 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.
ii. The RPO is responsible for initiating the registration process in accordance with the following requirements as appropriate:
a) Amend the registration to include any new X-ray machine within 30 days of initial operation.
b) Amend any changes to the registration (RPO, machines, locations of machine use, etc.) within 30 days of the change.
c) Maintain the certificate of registration issued by the applicable regulatory agency in his/her office or designated radiation files.
3. Procurement
i. The following steps are required to purchase / ease any new X-ray producing machines:
a) The RPO shall be notified of any plans to purchase / lease radiation-producing machines before the machine(s) is ordered.
b) 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:
The manufacturer,
Equipment Model,
Planned use, and
Scheduled delivery of the machine by the person requesting the purchase / lease.
4. Receiving
i. 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 4) or equivalent if dictated by a local regulation.
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5. Storage
i. X-ray machines which must be stored until placed into service shall be stored in a designated storage area secured to prevent unauthorized removal.
a) The X-ray machine shall be locked / tagged out.
6. Installation
i. The RPO shall be notified by the facility representative when the manufacturer is scheduled to install (start-up) the machine.
ii. No persons shall operate a radiation-producing machine until it has been installed by the manufacturer’s representative and released to the RPO.
iii. 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 4).
7. Maintenance / Repair
i. 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.
ii. All maintenance/repair work shall be documented and reviewed with the RPO.
iii. Any modification to an X-ray machine is prohibited unless documented authorization is obtained from the manufacturer or their designated representative.
8. Machine Warning Devices and Labelling
i. A readily visible warning light labelled with the words "X-RAY ON" must be illuminated only when the tube is energized.
a) The light must be fail-safe (i.e., failure of the light bulb must shut down the X-ray machine).
ii. Each X-ray machine must be labelled with the following signs bearing the radiation symbol and the words:
a) "CAUTION - HIGH INTENSITY X-RAY BEAM" on the X-ray source housing.
b) "CAUTION RADIATION - THIS EQUIPMENT PRODUCES RADIATION WHEN ENERGIZED" near any switch or keyboard that energizes an X-ray tube.
iii. 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."
iv. Each registrant shall post in a place for all workers to read a “Notice to Employees.”
9. Inspections
i. At intervals not to exceed 12 months, all X-ray machines shall be visually inspected and inventoried by the RPO or designee.
a) Records documenting this visual inspection and inventory shall be maintained by the registrant for inspection by the regulatory agency.
b) The original document shall be maintained by the Q-Chem RPO.
ii. Visual inspections shall include verifying the following:
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a) All labels are legible;
b) “Caution X-Ray Equipment” signs are posted at all the entrances; and
c) The “X-RAY ON” light is operational.
iii. All inspections shall be performed using the X-ray Machine Inspection Form (see Attachment 4) or equivalent if dictated by a local regulation.
10. Shipping / Relocation
i. Written authorization must be obtained from the RPO prior to the shipment offsite or relocation onsite of an X-ray machine.
a) 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.
11. Special Requirements for X-ray Diffraction Machines [Where Applicable]
i. The following requirements apply only to the X-ray diffraction machines, since these machines utilize an open beam configuration:
a) A safety interlock is required to prevent any part of an individual's body from entering into the primary X-ray beam path.
b) All unused ports must have a shutter that cannot be opened unless a collimator or a coupling is connected to the port.
c) 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.
d) 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.
12. Training
i. 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.
ii. The X-ray machine safety class shall at a minimum include the following:
a) Identification of radiation hazards associated with the use of the radiation machine;
b) Radiation warning and safety devices incorporated into the radiation machine;
c) Operating and safety procedures for the radiation machine;
d) Symptoms of an acute localized exposure; and,
e) Proper procedures for reporting an actual or suspected exposure in excess of the exposure limits.
13. Records and Documentation
i. 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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8.8. APPENDIX H
INDUSTRIAL RADIOGRAPHY
1. Description
i. 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.
ii. 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.
2. License and Regulations
i. 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.
3. Dose Limits and Monitoring
i. 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].
ii. 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.
4. Radiography Auditing
i. 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 7) or equivalent if dictated by a local regulation.
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8.9. APPENDIX I
HOW TO DETERMINE ANNUAL RADIATION EXPOSURE
1. Radiation Workers
i. 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.
ii. 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.
iii. 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.
iv. 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.
2. General Public
i. 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.
ii. 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.
iii. 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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8.10. APPENDIX J
NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM)
1. Description
i. 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.
ii. 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.
2. License and Regulations
i. 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.
a) NORM monitoring shall be performed regardless of a lack of regulatory guidance to determine if any potential occupational exposure exists.
3. Dose Limits
The following maximum radiation dose limits shall apply:
i. Radiation worker: 50 000 µSv/yr [50 mSv/yr].
ii. Member of the public: 1000 µSv/yr [1 mSv/yr].
iii. Embryo / foetus in a declared pregnant woman: 5000 µSv for the pregnancy.
4. General Requirements
i. 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.
ii. Once this equipment is opened, an internal survey shall be performed to verify that the surface contamination limits are not exceeded.
iii. 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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5. Instrumentation
i. 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.
a) This instrument is not capable of detecting alpha or beta radiations.
ii. 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.
a) This instrument is appropriate only for internal surveys.
6. Surveys
i. When performing external surveys using the gamma scintillator, the following shall be considered:
a) The detector is very fragile.
b) The most sensitive part of the detector is the flat front end.
c) This instrument picks up background radiation (remember to subtract background radiation from readings).
d) 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.
e) Readings must be documented in micro Roentgens per hour (µR/hr).
ii. These readings are best used to help identify suspect areas of concern.
a) The gamma scintillation detector shall pick up the low level gamma rays that are penetrating the equipment wall.
b) 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.
iii. When performing internal surveys using the pancake detector, the following shall be considered:
a) The Mylar window on this detector is very thin and fragile.
b) When using the open window, the detector is detecting alpha, beta, AND gamma radiations.
c) By turning the detector over and using the back side, the detector shall only detect gamma radiation.
d) 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.
e) This instrument shall also pick up any radiography being performed in the area.
f) Readings shall be documented in counts per minute (cpm).
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7. NORM Limits
i. 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:
a) Gamma contamination: 50 µR/hr [including background radiation levels]
b) Fixed alpha, beta gamma contamination: 5 000 dpm
c) Removable alpha, beta gamma contamination: 1 000 dpm
d) Removable contamination shall be checked by taking a smear sample inside the piece of equipment to determine contamination levels
e) The smear sample is to cover approximately 100 centimeters
8. Personal Protective Equipment
i. 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:
a) Half-face respirator with HEPA cartridges, e.g. P-100;
b) Disposable paper suit (e.g., Tyvek®, etc.);
c) Gloves (leather or rubber); and,
d) Disposable boot covers.
9. Shipping of NORM-contaminated Equipment
i. The RPO shall authorize the shipment of any NORM-contaminated equipment offsite to ensure that the receiver is qualified to accept such equipment.
ii. Any NORM-contaminated equipment that is shipped offsite shall be labelled with appropriate hazard warning.
10. Decontamination
i. 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.
ii. Companies performing NORM-decontamination activities are required to have a specific license which authorizes the company to perform such activities.
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9. REVISION HISTORY
Rev. Issue Date Amendment Description Prepared By Reviewed By Approved By
7 18-Feb-18
Periodic Revision Added requirement of manual PR creation for
radioactive materials (sec. 4.3. (i). (d) & (e)) Added MM No. for Supervised Radiation Area
Included section on Procurement of Radioactive Sources / Equipment into the main procedure and not as part of an Appendix. (Section 4.3)
Included a new form for initiating the procurement of Radioactive Sources / Equipment. (Attachment 8)
Lloyd G Askham
Amit Parikh Moideen Kutty Chandrasekhar
G Naidu Job S
Jeyapandian Hitesh Patel
Micah J Sperling Nitin
Saraf C Umesh
Akmal Rana Ahmed J Al-
Subeay Anthony Dugat
Carl Poldrack Roehl
Bartolome Saleh Abdulla
Anuraag Jamal I Khalil
Kevin C Kabell
Ali Al-Marri Abdulla Al-
Khulaifi
5 18-Sep-13
Included definition of a Radiation Clearance Certificate (RCC).( Section 3)
Included new requirements for the transportation of radioactive sources into QP Premises. (Section 4.9.4 and 4.9.5)
Included “isotope injection for leak identification” as an RCC required job. (Section 4.10.1)
Included “Procedure for obtaining an RCC”. (Section 4.10.3)
Included procedure/process for permitting radiation work. (Section 4.10.5)
Updated radiation program review details and outcomes, including changing the Procedure revision frequency to 2 years in line with RIM requirements. (Section 4.18.2 and 4.18.4)
Updated the language in Appendix B “Radiography Announcements” to clarify the medium (common radio channel) for communicating radiography jobs.( Appendix B.)
procedure meets requirements of EHS-5150 (Gap Analysis conducted). Also made some
Lloyd G Askham
Sara Khamis / Amit Parikh
Carl Poldrack Carl Poldrack
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minor formatting changes to document, including company logo. (General)
Updated JSA meeting requirements. Included topics to be addressed during the JSA meeting.( Section 4.11.2)
Changed the PA announcement requirement before radiography from 30 minutes to 15 minutes. Minor formatting to the message. (Section 4.11.13 and Appendix B)
Program Review Section included. Also included the language as contained in EHS-5150 on this subject. (Section 4.18)
Modified the Radiation Clearance Certificate (RCC) to include minimum barricade distance. Also made adjustments to the form to allow electronic input of most data. (Attachment 1)
Personal Dose Record Form – made some formatting changes and logo changes. (Attachment 2)
Deleted Attachments 4 and 5 (Surveyor 50 Radiation Standard and PEN Dosimeter Standard respectively) from the procedure (Obsolete). (Attachments)
3
04-Jul-11
Included RLOC plant within scope of the procedure. (Section 2)
Updated RPO & Designated RPO details for both Mesaieed & Ras Laffan sites. (Section 4.4)
○ Normal two year review cycle for procedures. ○ Only minor change made to procedure as
indicated below:
Lloyd G Askham
Sara Khamis / Amit Parikh
Carl Poldrack
2
04-Aug-10
Changed the medium of communicating radiography warning announcements. PAGA system no longer used. All communications shall now be through Q-Chem common radio channel. (Section 4.12.13)
Lloyd G Askham
1
01-Mar-08
Changes to include Corporate Policy requirements; including the following:
○ Naturally Occurring Radioactive Materials (NORM) assessment & measurement in process sludges of Ethylene Unit(Section 4.13)
Sealed source wipe sampling requirements for devices containing radioactive materials. Wipe sampling standard developed [HSE-SAF-STD-00-0015].( Appendix F8, Attachment 10)
