MURPHYMERAUX REFINERY

OIL U.S.A., Inc.POLICIES AND PROCEDURES

SSP-0028

Date Issued:09-22-93

Supersedes:New

Page 1 of 21

TITLE:

Worker Protection Plan for Naturally Occurring Radioactive Materials

I.POLICY

It is the policy of Murphy Oil USA, Inc. (Murphy) that employee exposure to Naturally Occurring Radioactive Material (NORM) shall be minimized to a level that is as low as reasonably achievable. Exposure control shall be accomplished through the use of engineering controls, personal protective equipment and worker education. Employees and contractors of Murphy shall not undertake to perform any task with the known potential for NORM exposure, without the proper protection and training necessary to perform the work safely.

The Safety Department and the Environmental Control Department are responsible for maintaining, approving, and incorporating revisions to this policy and procedure. All proposed revisions must be submitted to Murphy’s management for consideration and/or incorporation. Any questions regarding NORM protection should be directed to Murphy’s Supervisor of Safety.

II.PURPOSE AND APPLICABILITY

A.PURPOSE

This procedure establishes the requirements and methods necessary to ensure worker protection from the potential hazards of NORM exposure while working at the Murphy facility. This document supersedes and cancels all previous memoranda and programs pertaining to this subject.

B.APPLICABILITY

This program is applicable to Murphy employees and its vendors or contractors involved in any work process that may result in exposure to NORM as defined in the text of this procedure.

III.REFERENCES

A.OSHA Regulation 29 CFR 1910.96

B.LAC Title 33, Part XV, Chapter 14.

C.LAC Title 33, Part XV, Chapter 10.

D.LAC Title 33, Part XV, Chapter 4.

IV.DEFINITIONS

A.Confirmatory Survey - The initial radiation survey performed by a potential licensee to determine if a facility is exempt from the NORM regulations.

B.Detector, Geiger-Mueller (G-M) - Highly sensitive, gas filled radiation detecting device that operates in the Geiger-Mueller portion of the gas ionization chamber characteristic curve at voltages high enough to produce avalanche ionizing particles.

C.Detector, Scintillation - The combination of phosphor, photomultiplier tube, and associated electronic circuits used for counting light emissions produced in the phosphor by ionizing radiation.

D.Dosimeter, Pocket - An instrument used to detect and measure accumulated gamma radiation exposure.

E.Dosimeter, TLD - The thermoluminescent dosimeter is a personnel monitoring device composed of lithium or calcium fluoride crystals capable of absorbing and storing the energy associated with radiation.

F.LDEQ - The Louisiana Department of Environmental Quality.

G.Microroentgen - A unit of radiation exposure that is equal to one-millionth of a roentgen.

H.NORM - An acronym for Naturally Occurring Radioactive Material, with regards to the oil and gas industry, radium-226, radium-228, and their radioactive daughters.

I.OSHA - The Occupational Safety and Health Administration.

J.Radiation - Energy in the form of electromagnetic waves or particles from the nucleus of radioactive atoms, occurring in one of four forms: alpha, beta, gamma or neutrons from fission.

K.Release Survey - The radiation survey that is required to release either equipment or land for unrestricted use.

V.RESPONSIBILITIES

A.MANAGERS AND SUPERVISORS

1.All Murphy managers are to ensure that their supervisory personnel clearly understand this policy and procedure, and that supervisory personnel enforce the requirements of this procedure among their work force.

2.Supervisors are to ensure that employees with the potential for exposure to NORM conform to the requirements of this program, and strictly adhere to this policy and procedure.

3.Each supervisor is responsible for determining if his/her employee has been assigned to work in an area that will result in exposure to radiation levels that exceed allowable limits of exposure (See Section VII. A.2. In addition, the supervisor shall be responsible for requesting and/or supplying equipment necessary for engineering controls (e.g., ventilation) and personal protective equipment (PPE) for employees working in “restricted areas”.

4.Supervisory personnel whose employees are required to work in areas with the potential for exposure to NORM must actively participate in Murphy’s NORM protection training and instructional programs.

5.Managers or supervisors securing the services of contractors or vendors, are responsible for ensuring that these individuals understand and comply with the requirements of this program.

6.Supervisors will conduct meetings with employees just prior to entry into a restricted area. These meetings shall consist of a review of; the possible radioactive area location(s); recommended work practices while in the area; and, the PPE and specific employee responsibilities necessary to ensure employee safety while in the area.

B.EMPLOYEES

1.Employees are required to be cognizant of their work environment and the associated conditions that may require protection from NORM.

2.Employees that are required to enter a restricted area must actively participate in training and educational programs as required by and described in this procedure.

3.Each employee must adhere to the requirements of this procedure, and must immediately report any defect in their PPE, or any circumstance that resulted in, or may result in, direct contact with radioactive material. Such reports should be directed to the employees supervisor and/or the Safety Department.

4.No employee shall undertake any activity that requires active participation in the NORM decontamination of fixed equipment, piping, or any land area within Murphy’s facility, for unrestricted use.

C.SAFETY DEPARTMENT

1.The Supervisor of Safety shall select the PPE to be used by employees for radiation protection. Consideration shall be given to the level of protection offered by the device, employee acceptance when using the device, and cost effectiveness.

2.The Safety Department shall be responsible for assisting in the implementation of the requirements of this program. In addition, this procedure will be periodically reviewed by the Supervisor of Safety to ensure its adequacy in protecting employees from radiation hazards in the workplace.

3.Murphy’s Safety Department will ensure that routine, periodic inspections of Murphy operations are conducted for the purpose of determining compliance with the requirements of this procedure. The results of such inspections will be formally documented, reported to management, and maintained on file.

4.All record keeping (See Section VII E.) such as radiation surveys, equipment calibration, incident reports, training documentation, etc., shall be formally documented and maintained on file in the Safety Department and/or in the Environmental Control Department. Original copies of surveys and calibration data will be maintained by the Manager of Planning and Engineering.

5.All radiation protection training will be performed by or under the supervision of Murphy’s Supervisor of Safety.

D.CONTRACTORS

1.All contractors working at Murphy whose job requires that they must enter a restricted area, must comply with this policy and procedure, and all applicable state and federal regulations relative to NORM and employee radiation exposure.

2.Any contractor whose services have been secured for the purpose of NORM decontamination of equipment or land, to allow for their unrestricted release, must be specifically licensed for this activity by LDEQ’s Radiation Protection Division. The contractor shall present evidence of this specific license, its employee NORM protection plan, and documentation of employee training to Murphy’s Supervisor of Safety prior to initiating any decontamination task.

VI.EMPLOYEE TRAINING REQUIREMENTS

A.All employee and supervisory training shall include a presentation of subject matter that must include, but not necessarily be limited to, the following:

1.The adverse health effects associated with exposure to radioactive material or radiation, including biological risks to an embryo or fetus;

2.The precautions and procedures developed by Murphy that are necessary to minimize radiation exposure;

3.The purpose and function of protective devices to be used by employees working in restricted areas;

4.The Louisiana radiation regulations and licenses as applicable to the protection of personnel from exposure to radiation or radioactive material present in restricted areas;

5.Instruction as to employee responsibility to report to Murphy any condition which may lead to or cause a violation of the Louisiana radiation regulations, or unnecessary exposure to radiation or radioactive material;

6.The procedure and system of priorities to be followed in the event of an emergency that would require rapid egress from the restricted area or that would result in exposure to radiation or radioactive material;

7.That employees will be provided with the results of radiation exposure reports to the extent that exposure monitoring is required and/or performed; and,

8.The details of this policy and procedure as it relates to the employee’s protection and/or their responsibilities relative to minimizing exposure to radiation and radioactive material.

B.The extent and frequency of training will be determined by Murphy’s Supervisor of Safety in accordance with regulatory requirements. In developing the schedule for retraining and the content of training programs, the Supervisor of Safety will consider the nature and severity of each potential radiation hazard that will be encountered by Murphy employees.

C.Vendors and contractors shall supply training and instruction as described in this section to their employees. This training and the associated documentation will be reviewed by Murphy’s Supervisor of Safety prior to any contractor or vendor employee beginning work in a restricted area.

VII. GENERAL PROCEDURAL REQUIREMENTS

A.DESCRIPTION AND SCOPE OF NORM RELATED ACTIVITIES

1.External “Confirmatory surveys” performed at the Murphy facility in September of 1992 revealed that no area or equipment at the refinery exceeded the NORM threshold limit of 25 microroentgen per hour (R/hr). The highest reading detected at any location was 22 R/hr (background not subtracted) at the south head of a heat exchanger at the oily water stripper unit.

2.Prior to personnel entering any unit vessel suspected of containing NORM above the threshold limit, a designated operator or supervisor shall perform a screening survey of the units interior in accordance with the methods described in Section VII.B. Such surveys will be performed prior to Murphy employees or contractors performing work on any unit, piping, or equipment that is suspect of potential NORM contamination. Areas within the refinery that may accumulate NORM, and that must be screened prior to entry or work, include but are not limited to: Oily water unit, waste water piping; CPI/API separators; distillation unit crude oil exchangers; slop oil tanks; desalters; crude oil storage tanks; fuel gas knock-out drums, flare knock-out drums; all equipment in the #2 FCC gas plant excluding the debutanizer and associated heat exchangers and accumulators; and, the crude overhead heat exchangers, accumulators and non-condensible process equipment.

3.The results of these surveys will be recorded on the form supplied as Attachment 1. In the event that the interior screening surveys reveal an exposure level of 25 R/hr above background the details of this policy and procedure relative to worker protection shall be implemented. No Murphy employee shall participate in any activity that contributes to the NORM decontamination of the unit, equipment or piping for the purpose of releasing these items for unrestricted use.

The scope of work for Murphy employees will be limited to normal maintenance evolution activities (e.g., changing or repairing malfunctioning equipment, cleaning trays, performing scheduled maintenance, etc.). NORM decontamination for the unrestricted release of such equipment will be performed by contractors that have obtained a specific license for this activity by LDEQ’s Radiation Protection Division.

4.Employees must be cognizant of all potential health and safety hazards in a restricted area and adhere to the requirements of all Murphy safety and health procedures.

B.SCREENING SURVEYS

1.Surveys as required in Section VII.A.2. will be performed prior to initiating any maintenance or work activity at a location within the refinery that may result in exposure to NORM above the threshold limit.

2.A Ludlum Model 44-2 scintillation detector and Model-3 meter capable of reading 1 - 500 R/hr will be used for screening surveys. This instrument must be calibrated at least every six months and after each servicing. Calibrations will be performed by persons licensed by the State, or the US Nuclear Regulatory Commission. Calibrations will verify the accuracy of the instrument(s) to within 20% of the true radiation level.

3.The operator, after verifying instrument response and operation in an area exhibiting normal background radiation levels, will take precautions to protect himself/herself should there be a reasonable suspicion that NORM levels will exceed the threshold regulatory levels. At a minimum, the surveyor will wear gloves, and a full face air purifying respirator with HEPA filter cartridges. If vessel entry is required the surveyor must use coveralls (waterproof coveralls are required if wet conditions are anticipated) and boots or shoe covers. Murphy’s Confined Space Entry Procedure shall be followed when applicable to vessel entry.

4.The equipment will be surveyed by placing the detector as close as possible to the surface but at a distance of no more than 1 cm. The survey will include at least 20% of the equipment surface and readings will be recorded at a minimum of three locations.

5.All hotspots (i.e., locations with readings of 25 R/hr above background) must be marked on the equipment to alert workers of their location.

6.The results of each survey, including background, readings, survey locations, hotspot locations, date, time, operator, instrument description and serial number, and calibration information must be formally documented. This information will be provided to the supervisor that is responsible for the work activity to be performed at this location. Copies of this survey information will be retained on file at the Safety Department office.

C.WORKER PROTECTION GUIDELINES

1.If a portion of the equipment on which work is to be performed is greater than or equal to 25 R/hr above the background radiation level, then that equipment shall be considered to be contaminated with NORM and the following Worker Protection Guidelines must be implemented.

2.Prior to initiating work, the area to be restricted will consist of two zones, the Exclusion Zone and the Decontamination Zone. The NORM contaminated area where maintenance or repair work is to be performed shall be considered an Exclusion Zone, the access to which will be limited to personnel who have satisfied the training requirements of this procedure. The number of personnel entering any restricted area (i.e., exclusion zone or decontamination zone) must be minimized at all times.

3.The Exclusion Zone will be identified with the erection of barrier tape (tape should read “Caution Radiation Area”) and the conspicuous posting of caution signs that will notify workers of the presence of a radiation source. Caution signs will conform to the requirements set forth in LAC 33:XV.422. Each sign shall be a tri-foil design as depicted on Attachment 2, and shall use the standard radiation caution colors (magenta or purple on yellow background). Other appropriate warning signs shall be posted as deemed necessary by Murphy management in order to ensure employee protection.

4.A decontamination zone shall be established immediately outside the exclusion zone. This area shall be segregated from other work areas with the use of yellow “caution” barricade tape and the warning signs discussed in the previous paragraph shall be conspicuously posted around the area. This zone will be utilized for personnel and tool decontamination.

All personnel exiting the exclusion zone must adhere to the decontamination procedures as established in Section VII.D. The decontamination zone must be manned with support personnel that will assist in the decontamination process. Decon support personnel shall wear appropriate PPE to prevent contamination and or direct contact with radioactive material. Support personnel in the decon zone will also ensure that non-authorized personnel are not permitted to enter the restricted areas.

5.Prior to beginning operations in the exclusion zone, the work process and work area will be examined by the responsible supervisor or operator to determine what engineering controls may be installed to minimize employee exposure. Whenever feasible, engineering controls (e.g., exhaust ventilation, radiation shielding of hotspots, etc.) shall be installed as the primary means of employee protection. All exhaust ventilation shall be filtered through HEPA filtration prior to exhausting to the atmosphere or to other work areas. The use of plastic drop cloths or barriers shall be employed whenever necessary to prevent the spread of contamination to areas outside of the restricted area.

6.The level of personal protection to be utilized will be determined on a case by case basis. As a minimum, employees will be required to use Level B protection as described in Murphy’s HAZWOPER training manual. In the event that air purifying respiratory protection is deemed adequate (e.g., for use by support personnel in the decontamination zone) it shall be equipped with HEPA filter cartridges. Coveralls, gloves and boots used by employees in the exclusion zone and decontamination zone must be impermeable to liquids that may be present if such conditions exist.

7.It is highly unlikely that the long term permissible exposure levels, as identified in the referenced OSHA and LDEQ regulations, will be encountered during maintenance/repair operations at Murphy. Therefore, employee monitoring with dosimetry devices or TLD badges will be at the discretion of Murphy’s management and will be considered mandatory if there is reason to believe that significant exposure will be experienced.

As required by the referenced standards a significant exposure will be defined as an individual exposure in excess of the limits as specified in the following table:

BODY PART EXPOSED / REMS PER CALENDAR QUARTER
Whole body; head and trunk; active blood forming organs; lens of eyes; or gonads. / 1-1/4
Hands and forearms; feet and ankles. / 18-3/4
Skin of whole body. / 7-1/2

8.Employee stay time in the restricted area or exclusion zone will be kept to a minimum in order to limit the potential for exposure to radioactive material.

9.Eating, drinking, smoking, chewing and the application of cosmetics are strictly prohibited in the exclusion and decontamination zones. For this reason food, beverages, chewing gum, tobacco products, and cosmetics are not allowed in the decon or exclusion zone.

10.Once employees have exited the decontamination zone they must thoroughly wash their hands and face prior to eating or smoking.