Procedure No. SAF 067 Rev. No. 9

Certified / Toledo Refinery / Procedure No.:
SAF 067
Effective Date:
June 29, 2009 / Radiation Safety Program and Procedure / Rev. No.: 9
4/1/2009
Written By:
Jean Mlynek / Auth. By: D. Durnwald
(signature on file) / Page 1 of 9
SCOPE / Radioactive isotopes such as Cesium 137 (Cs-137) are used in the refinery to measure vessel product levels and for non-destructive testing and inspection.
HEALTH
Special PPE & Special Hazards / Over-exposure to ionizing radiation from these sources has the potential to alter and even destroy biological cells. Any potential radiation exposure will be kept to As Low As Reasonably Achievable (ALARA).
SAFETY / Hardhat, safety glasses, gloves and survey meter. Personal dosimeters and film badges may also be required depending on possible exposure levels.
REFERENCE
DOCUMENTS / Nuclear Regulatory Commission 10CFR Part 20
Nuclear Regulatory Commission 10CFR Part 31
Ohio Dept of Health, Bureau of Radiation Protection
SPECIAL MATERIALS & EQUIPMENT / Radiation Survey Meter
Radiation Warning Signs
Pocket Dosimeter
QUALITY / Annual factory calibration of survey meters, timely leak tests. Certified Radiation Safety Officers (RSO’s).
ENVIRONMENTAL / All nuclear sources are shielded to protect unnecessary release of radioactive materials into the environment.

OVERVIEW

The Radiation Safety Officer (RSO) for the Toledo Refinery is Jean Mlynek. Bob Sauer is the alternate RSO. The Operations Group (Asset) will utilize the nuclear sources for level gauging.

Radiation Protection Principles

Distance from the source offers the best protection from over-exposure to ionizing radiation. Radiation intensity will decrease proportionately to the distance squared.

Time is the second way to control radiation exposure since the amount of exposure is directly proportional to the time spent in the radiation area. For example, the radiation received in a ten-minute exposure is ten times greater than during a one-minute exposure.

Shielding is a third way to control radiation exposure. Dense material such as lead, steel, concrete and even water can absorb radiation before the radiation can reach your body.

Planning is a fourth way to control radiation exposure. Plan you work activities around radiation sources so that you spend the shortest time possible near the source to keep your exposures as low as reasonably achievable (ALARA).

Permanently mounted radiation level gauges

On some process units there are instruments that use a radiation source to determine vessel contents level. The radioactive material is contained in a doubly encapsulated stainless steel assembly, which is loaded into a lead lined source holder. The source holder is mounted on a vessel with the shutter opening pointing to a target device, which transmits an electronic signal to the ControlCenter. The Ohio Department of Health (ODH) licenses radioactive materials and x-ray machines. Ohio became an Agreement state in July, 2000. Therefore, the NRC has given authority to Ohio to oversee radioactive devices licensed in Ohio. A list of these devices is included in this procedure which gives the source location, source material, and activity. (See Attachment 1)

Page 1 of 9

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Procedure No. SAF 067 Rev. No. 9

1.0Procedure /
  • Be aware of the location of fixed nuclear gauging devices in your area. Attachment 1 of this procedure lists all locations.
  • Sources will be identified by the conventional three bladed radiation symbol. The blades will be purple on a yellow background. The sign will read: “Caution, Radioactive Materials”.
  • The RSO, alternate RSO, or RSO authorized person, will perform visual checks of all nuclear sources every six (6) months. Leak tests will be performed every three (3) years on most of the sources. Coker 2 sources will be leak-tested every six (6) months as well as the Niton Analyzers
  • Persons entering a vessel before the radiation source has been turned off or drawn up into its protective housing cause the most common accidental radiation exposure. For this reason, a Safe Work Permit for any vessel with a radiation device mounted on it must include the lockout of all radiation devices.
  • Lock-out will be accomplished by the following steps:
The Operations or Maintenance Supervisor will co-ordinate the lock out of the nuclear source. The RSO will be notified that the source needs to be locked out. The source will be locked out by or under the direction of the RSO or alternate RSO. The RSO, alternate RSO, or RSO authorized person, isolates and locks the radiation sources. The key to these locks is placed onto a u-bolt with a tag. The RSO places a purple lock onto the u-bolt securing the key. The purple lock remains on the u-bolt until the maintenance is complete and the source is ready to be put back into service. The RSO or designeewill re-energize radiation sources when determined that work is complete.
a)The RSO, alternate RSO, or RSO authorized person,will sign and/or initial all required energy isolation forms to validate that the source is secured. A tag and the key will be car-sealed to the Operations (Asset) LOTO board which communicates the source location and RSO signature. The source LOTO keys are kept in the HSSE building when sources are not locked out attached to a board in the Laboratory.
b)The RSO or RSO authorized person will use a survey meter to check for radiation levels before an entry permit is granted.
c)The entry permit must note that the radiation source has been locked out and that the vessel is free from harmful levels of radiation.
  • When work in the vessel is complete and the vessel closed up, the device may be activated by having the RSO, alternate RSO, or RSO authorized person, remove his/her lock and open the shutter.
  • The refinery’s Ohio Department of Health (ODH) license imposes limits within which nuclear devices may be used. One of the limitations is that only those who are specifically licensed by the ODH may remove the source holder from its mounting. No one in the refinery is licensed to remove a radiation source. If a source needs to be taken down from its mounting brackets, contact the Radiation Safety Officer. The Radiation Safety Officer will make arrangements with the manufacturer of the source holder or another licensed entity to supervise the removal of the source holder.

2.0Emergency Procedures / FIRE
  • In case of a fire, handle the immediate emergency first, and inform fire-fighting personnel that radioactive sources are in the area. As soon as the immediate emergency is taken care of:
a)Isolate the area around the source in all directions.
b)Notify the RSO or alternate RSO.
c)PPE precautions. Until the radiation levels can be determined with a survey meter, the surveyor shall wear respiratory protection and other PPE to include: gloves, level B/C and a personal pocket dosimeter. When finished, place contaminated gloves, tongs and clothing inside a plastic bag, wash immediately and shower as soon as possible. If the exposure potential occurs inside an enclosure or building, turn off all fans, air conditioners or air moving equipment.
IF: The radiation profile is normal (less than 5 millirem/hour at one foot from the source), the following steps must be followed:
  • Check the shutter mechanism for proper functioning
  • Leak test the unit
  • Inspect the source holder for any damage to the mounting hardware
If no problems are noted, the gauge may be placed back in service. If problems are noted, the RSO, or alternate, will make arrangements with the gauge manufacturer for safe removal, packaging and shipment of the source for repair.
IF: The radiation field is above normal limits, then the following steps must be followed by the surveyor:
  • Cordon off and make the area with radiation hazard signs at the 2 mrem/hour level.
  • Note the names of all personnel who may have been exposed.
  • Contact the gauge manufacturer for assistance in removal, packaging and disposal.
  • Leak test the unit for possible contamination.
  • Test the area around the nuclear gauge for possible contamination.
  • If tests indicate that the source holder has leakage, use rubber gloves and tongs to place plastic bags over anything suspected of being contaminated to prevent spreading the radioactive material.
  • The RSO will maintain complete records of the incident including all follow up done on site and in-hospital to the personnel involved.
FALL OR COLLISION
  • Isolate the area around the source 100 feet in all directions.
  • Notify the RSO or alternate.
  • The RSO will survey the source holder to check if the radiation profile is normal. The radiation profile should measure less than 5 mrem/hour at one foot from the unit with the shutter closed.
IF: The survey is normal, the following steps must be followed:
  • Insure the shutter on/off mechanism is functioning properly. If it is, lock it off.
CAUTION
Make sure the radiation beam is pointing away from personnel. If the shutter cannot be turned to the off position, block the opening with shielding material.
  • Leak test the nuclear gauge for contamination.
  • If the radiation is within prescribed limits, the source shutter mechanism is operating properly and there is no evidence of radioactive material leakage, then the gauge may be placed back in service. Contact the Radiation Safety Officer or alternate before moving any source. Remember, no source may be mounted or dismounted unless it is done under the supervision of someone specifically licensed by the NRC or an agreement state, such as the ODH.
IF: It appears that the lead shielding has been damaged, regard the source as having a radiation field present above allowable limits.
  • Cordon off and mark the area with radiation hazard signs at the 2 mrem/hour radiation level.
  • Obtain the names of the individuals who may have been overexposed.
  • The RSO or alternate will contact the NRC and the ODH immediately. That person shall also notify the gauge manufacturer so that arrangements can be made for the safe removal, packaging and shipment of the source. The RSO will maintain complete records, including all follow-ups done on site and in-hospital to the personnel involved.

3.0Emergency Phone Numbers / Bureau of Radiation Protection
Ohio Department of Health
246 North High Street
Columbus, OH 43215

Phone: 614-644-2727
Fax: 614-466-0381
Nuclear Regulator Commission
Region III
799 Roosevelt Road
Glen Ellyn, IL 60137
(301) 816-5100 or 301-951-0550 (staffed 24 hours a day)
Ohmart-Vega Corporation
4170 Rosalyn Drive
Cincinnati, OH 45209
(513) 272-0135 (emergency number)
(513) 272-0131 (business phone)
TN Technologies
2555 N I35 P.O. Box 800
Round Rock, TX 78680-0800
Phone (512) 388- 9100
Fax(512) 388-9200
Thermo Fisher Scientific- Niton
900 Middlesex Turnpike
Building 8
Billerica, MA01821USA
(800) 875-1578
4.0Radiographic Inspection /
  • Any radiographic inspection work performed in the refinery must be coordinated by the Inspection Department. The Inspection Department will coordinate the scope of work, timing and work location with the appropriate operating and maintenance supervisors, the radiographic inspection contractor and other affected departments.
  • The Ohio Department of Health (ODH) must license any radiographic inspection contractor employed by BP. The contractor must abide by the ODH rules and regulations as well as the Toledo Refinery site-specific Radiation Safety Program requirements.
  • The radiation area is to be roped off or barricaded. The area barricades shall extend far enough away from the source that exposure will be less than 2 mrem/hour outside of the roped off area.
  • The radiographic inspection contractor shall ensure the radiation area is clear of all other personnel prior to each exposure of the radiation source. The radiographic inspector shall patrol the perimeter of the radiation area to ensure that personnel are observing the radiation warning signs. The radiographic inspector shall have a survey meter with him/her to monitor exposure levels to ensure they are below 2 mrem/hour.
  • Whenever possible, the position of the source shall be such that the beam of radiation will be away from areas occupied by people. Beam spread shall be kept as small as possible by the use of shields.
  • All radiation source containers must be marked with the conventional radiation symbol. Sources must be locked in a secure location when not under the direct control of the radiographic technician.
  • The radiographic inspection contractor is responsible for all material brought on site.
  • No one shall enter a radiation area if an operating emergency exists until the radiographic inspection contractor has ceased operation and retracted the source so that the emergency can be handled. It is imperative that exposure is kept as low as reasonably achievable. One exception is the case where an ODH inspector may enter a radiation area for inspection purposes. The inspector must present identification, have a film badge and dosimeter and be made aware of the radiation field intensity that he/she is entering.

5.0Emergency Procedure /
  • In an emergency involving a radiographic source, priority must be given to human safety. The radiographic inspection contractor and Inspection Coordinator shall see that the area is evacuated to a distance where exposures are below 2 mrem/hour. They shall also take action to stop the spread of contamination and rope off and post signs to establish a safe boundary around the accident site.
  • The Inspection Supervisor or designee will notify the Radiation Safety Officer. Depending on levels of exposure, the Radiation Safety Officer may have to notify the NRC, ODH or other agencies.
  • Identify and isolate all personnel who might have received high exposures or who could have been contaminated.
  • The Radiation Safety Officer will maintain complete records of the incident, including all follow up done on site and in-hospital to the personnel involved.

6.0Training /
  • Basic radiation safety training will be given upon hire. Outline and content may follow the Ohmart guidelines, utilizing Ohmart videos. More detailed training will be given upon assignment to a job, which involves working around, servicing and using Gamma or X-ray sources.

7.0Monitoring /
  • A radiation survey meter is used every six months as part of the radiation survey. In addition, leak testing is performed every three (3) years. In the event of an emergency, the radiation survey meter and a pocket dosimeter will be used by the RSO or alternate RSO to evaluate the situation. Refer to section 2.0 for Emergency Procedures.
  • Personnel monitoring is not required. Past exposure monitoring records, as recorded on film badges, are available from the Industrial Hygienist.
  • There are no regulated or restricted areas for radiation within the Toledo Refinery. All employees must obey radiation signs and barricaded areas during x-ray procedures for inspection purposes or in the event of an emergency.

8.0Notices /
  • Copies of Nuclear Regulatory Commission (NRC) and Ohio Department of Health (ODH) required posters are found on the bulletin boards outside the Clockhouse on the south side, in the Laboratory on the hallway bulletin board.
  • All citations issued must be posted in the same area. Copies of regulations and current licenses can be found in the office of the primary RSO.

9.0Definitions /
  • Abbreviations:
eV - electron volts
KeV - thousand electron volts
MeV - million electron volts
  • Americium-241 (Am-241) – neutron ray; half-life of 433 years.
  • Cesium-137 (Cs-137) - gamma ray; emits rays of energy 0.66 MeV; half-life of 30.2 years.
  • Cobalt 60 (Co-60) - gamma ray; emits gamma rays of energy 1.17 MeV and 1.33 MeV; half-life of 5.3 years.
  • Dose-pocket dosimeter - small air filled ionization chamber that measures radiation dose by responding to ionization in the air.
  • Direct-reading pocket dosimeter, thermoluminescent (TLD) - dosimeter worn by a person to measure radiation dose. Contains radiation sensitive crystal that responds to radiation.
  • Electron volt - small amount of energy. Energy of x-rays is often given in units of electron volts.
  • Geiger counter - instrument used to detect radiation and to measure radiation dose.
  • Half-life - time it takes for half the atoms in a radioactive sample to decay. Half-life varies from a fraction of a second to billions of years.
  • Leak test - check for the escape of radioactive material from a source holder.
  • Millirem (mrem) - a measure of the dose to the human body tissues in terms of its estimated biological effect.
  • Radiation Area - area where a person could receive a radiation dose in excess of 5 mrem in any one hour or 100 millirem in any five consecutive days.
  • Radiation Safety Officer or alternate (RSO) - person who is responsible for overseeing radiation safety at the Toledo Refinery,
  • Restricted Area - area with access controlled for the purpose of radiation protection.
  • RSOAuthorizedPerson - a named and specific individual who is assigned duties and/or tasks by the RSO or alternate RSO. The authorized RSO will have an understanding of the radiation risks, hazards, and control methods before accepting any duties or tasks by the RSO or alternate RSO.
  • Sealed Source - radioactive material sealed in a capsule designed to prevent leakage or escape of the material.
  • X-ray - radiation similar to light but more energetic and more penetrating. Usually produced by bombarding a metallic target with electrons. X-ray sources are located in the QC Lab in the x-ray Lab area. Ohio Department of Health, Division of Radiological Health Services, Columbus, Ohio regulates these sources. The manufacturer will do any maintenance required on these devices. Operating procedures will be in accordance with or provided by the manufacturer.

See Attachment

ATTACHMENT 1

Nuclear Sources, Their Location, and Activity

# of sources /

Location

/

Activity

3 / Coker 2 - East Drum Bottom, Middle, Top / 10 mCi Co-60
3 / Coker 2 - West Drum Bottom, Middle, Top / 10 mCi Co-60
3 / Coker 3 - East Drum Bottom
Coker 3 - East Drum Middle
Coker 3 - East Drum Top / 5000 mCi Cs-137
1600 mCi Cs-137
2400 mCi Cs-137
3 / Coker 3 - West Drum Bottom
Coker 3 - West Drum Middle
Coker 3 - West Drum Top / 5000 mCi Cs-137
1600 mCi Cs-137
2400 mCi Cs-137
1 / Vac I - 1st Deck at Base / 200 mCi Cs-137
1 / Crude Vac 2 - Inside Tower Skirt / 1000 mCi Cs-137
8 / ESP – second deck at hoppers – 4 each on west and east hoppers / 100 mCi Cs-137
1 / FCC 1 - MainFractionatorTower / 1000 mCi Cs-137
1 / Coker 2 BubbleTower / 200 mCi Cs-137
1 / Portable Lead Analyzer for Paint and Coatings / 40 mCi Cd-109
1 / Portable Metal Alloy Analyzer – Inspection Dept. / 30 mCi Am-241
1 / Portable Metal Alloy Analyzer – Inspection Dept. / 45 mCi Am-241

mCi = millicuries (the quantity that radioactive material decays (1 Curie = 37 billion disintegrations per second).