Radiation Protection Program. Site Function: Ecology, Health and Safety Procedure No.: WYN Page: 1 of 28

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1 Procedure No.: WYN Page: 1 of 28 Preparer: Owner: Approver: Radiation Safety Officer Radiation Safety Officer EHS Hub Manager Revision Date Revision Number Revision History Details of Change 04/ New document. 02/ / / / Major revisions include: Added Hetes as RSO. Revised Monitoring section. Added instruments section. Revised Training section with MBO module and training elements. Added new Audit Program section and checklist. Added new Waste Management section. Added new Records section. Annual review completed. Major revisions include: Added Hannewald as RSO. New requirements added for x-ray machines. Added new Operating Procedure section. Revised Receipt Procedure with Safe Package Opening procedure. Added new Industrial Radiography section. Revised LOTO and confined space procedures. Revised Radiation Survey section. Revised Responsibilities section. Added Exclusion Distances in Emergency Data Table. Revised Emergency Procedures section. Revised Training section with new RSO, x-ray and nuclear safety course requirements. Added new survey form, receipt checklist, authorized user list in section 7. Revised Posting and Labeling section with new x-ray requirements and added radiation symbol picture. Annual review completed. Updated P&PO format. Minor editing changes. Added 90 day notification in Section Emergency notification changed to be consistent with reporting of other site incidents in Section Removed WYN hyperlink. Updated Exclusion Distance Table for source locations in Section 7.7. Annual review completed. Added new Section 5.10 on Installations. Added new Section 5.11 on Removals. Changed Section to amend 5 year frequency from requirement to recommended. Changed out of date unit references to in Emergency Data Table 7.7. Authorized Users List for Maintenance and Lockouts updated. Nuclear Survey and Lockout Form updated. Removed Example Occupational Dose Evaluation reference. Moved ALARA section under procedure heading. Annual review completed.

2 Procedure No.: WYN Page: 2 of 28 Revision Date Revision Number 09/ / / / / Details of Change Minor formatting changes. State of Michigan references updated. Annual review completed. Minor formatting changes. Removed D Hannewald as Alternate RSO. Rinke named as replacement. Removed minimum classroom hourly requirement for RSO training. Annual review completed. Updated storage locations for six unused gauges in WYR from storage container to Maintenance Building storage room. Updated Authorized Users for Lock Out. Annual review completed. Updated in reference in Added section provision for screening wipe test samples for contamination. Added sections & regarding X-ray interlocks and periodic testing. Revised to remove requirement to send copy of survey form to RSO. Revised Exclusion Distance in section to 10 feet for all gauges. Added section for X-ray emergency procedures. Revised recordkeeping provision for unit maintaining lockout survey documents. Revised section 6.6 to simply Exclusion Distance Data by example gauges with note on rationale. Replaced all references to Mockingbird Online with Learning Management System (LMS). Revised Radiation Program Audit Checklist in section 6.2. Annual review completed. Added bullet in which allows use of electronic copy SOP per guidance from MIOSHA. Radiation Program Audit Checklist revised for Annual review completed. Added section to clarify existing xray reporting requirements.

3 Procedure No.: WYN Page: 3 of PURPOSE To ensure that use of radioactive materials are controlled, workers and personnel in the area of radioactive devices are not exposed to any unnecessary radiation and that radioactive materials are not lost or released to the environment thereby creating a potential radiation hazard to unsuspecting personnel or the general public. Furthermore, BASF shall maintain all exposure to personnel and the environment As Low As Reasonably Achievable (ALARA), in accordance with Nuclear Regulatory Commission (NRC) guidelines under 10 CFR part 20 and the State of Michigan s Radiation Control Act Part 135, 1978 PA DEFINITIONS 2.1 AS LOW AS REASONABLY ACHIEVABLE (ALARA) Because the current science indicates that there is no safe level of radiation exposure and that increasing radiation exposures increase the risk of adverse effects, the NRC mandates that all licensees ensure that radiation exposures are As Low As Reasonably Achievable. 2.2 INDUSTRIAL RADIOGRAPHY A process that involves the examination of the macroscopic structure of materials by nondestructive methods utilizing sources of radiation. 2.3 RADIATION SAFETY OFFICER (RSO) Person licensed and authorized to oversee the installation, use, relocation, inventory, maintenance, storage and leak tests of all devices containing radioactive materials. RSO also ensures the licenses are current. The Wyandotte Site s RSO is Derek Hetes, Ecology Services Department (x5282; Cell ). The alternate RSO is George Rinke (x6562; Cell ). 2.4 RADIOGRAPHER An individual who performs or who, in attendance at the site where sources of radiation are being used, personally supervises industrial radiographic operations and who is responsible to the licensee or registrant for assuring compliance with the requirements of these rules and all license or registration conditions.

4 Procedure No.: WYN Page: 4 of ROENTGEN Measure of the radiation field intensity in air. 2.6 ROENTGEN EQUIVALENT MAN (REM) Amount of radiation dose to body tissue in terms of its estimated biological effect compared to a dose of one roentgen of x-ray. Generally reported as millirems (mrem) which is equivalent to 1/1000 of a rem. 3. SCOPE 3.1. This radiation safety standard applies to the administration, procurement, and use of all radioactive materials, including nuclear gauges, detectors and x-ray machines, at the Wyandotte site which are covered either by the NRC s nuclear material license or Michigan s radiation machine certificate. 4. PROCEDURE 4.1. ALARA PHILOSOPHY In keeping with radiation protection philosophy and current regulatory requirements, BASF will maintain all exposures to personnel and the environment ALARA. Exposures will be maintained ALARA by minimizing source strength, using sufficient shielding, minimizing personnel time spent near the sources and by maximizing the distance from radioactive sources POSTING AND LABELING REQUIREMENTS NUCLEAR GAUGES Each device containing radioactive material shall be labeled with the three bladed radiation symbol (seen at right) and the word "CAUTION or other appropriate hazard warnings. Existing labeling supplied by the manufacturer may be used to meet this requirement, if appropriate.

5 Procedure No.: WYN Page: 5 of Any area where the radiation level is 5 mrem/hr or greater at least 12 inches away from the source must be posted with a "CAUTION -RADIATION AREA" sign Man-ways or other accesses to any vessel or enclosure where a nuclear gauge is used do not require posting with signage due to site standards controlling access into such equipment Each unit with nuclear sources must post the NRC Form 3, NOTICE TO EMPLOYEES in a conspicuous and commonly trafficked area such as on employee or general information bulletin boards Each unit with nuclear sources must post a notice in a conspicuous and commonly trafficked area notifying personnel that the following documents can be found in the EHS Central File Room: A copy of the NRC regulations. A copy of the Wyandotte site license and Radiation Protection Program. Any notice of violations regarding radiological working conditions ANALYTICAL X-RAY EQUIPMENT All analytical x-ray equipment shall have a label bearing the conventional radiation symbol and the words CAUTION: THIS EQUIPMENT PRODUCES RADIATION WHEN ENERGIZED or words with similar intent near any switch that energizes the x-ray tube X-ray equipment shall have a warning light that indicates "X- RAY ON" when the equipment is producing radiation.

6 Procedure No.: WYN Page: 6 of Each unit using analytical x-ray instruments shall ensure that each of the following are posted at the equipment: State of Michigan Form RSS-100, NOTICE TO EMPLOYEES Current version of the site s Radiation Machine Registration Certificate Equipment Operating Procedures Or, in lieu, of a hard copy operating procedure, it is acceptable to post a notice informing employees where an electronic copy of procedure may be obtained RADIATION MONITORING PERSONNEL MONITORING Routine personnel monitoring for gamma radiation is not required during normal use, installation, relocation, or removal of radioactive gauges, since the radiation levels are low There are no personnel on site expected to exceed 10% of the applicable annual limits. The RSO will perform a prospective evaluation demonstrating that unmonitored individuals are not likely to receive, in one year, a radiation dose in excess of 10% of the allowable limits or we will provide dosimetry results to demonstrate compliance with NRC requirements 10 CFR part If the RSO determines from the initial radiation survey and anticipated working conditions that any employee is likely to receive a dose of 100 mrem in a calendar year, then such individual will be limited to specified times and distances when working in the vicinity of a nuclear gauge.

7 Procedure No.: WYN Page: 7 of Routine personnel monitoring is required on those employees working with open beam x-ray producing equipment (i.e. Niton XL3T). The following requirements apply: Quarterly reports received from Landauer must be communicated to applicable users via posting on a safety bulletin board, providing individual s copies of report or reviewing in a safety meeting or huddle. A copy of the quarterly reports received from Landauer must be forwarded to the Site RSO. Site RSO will review results and follow up accordingly if results exceed a threshold value or appear to be inconsistent with expected exposures in any way. Site RSO will issue an annual summary report of exposures to each applicable user and to unit management unless results exceed a threshold value which would require quarterly reporting. All personal monitoring records and reports are kept in the EHS central files RADIATION SURVEYS A radiation survey which measures radiation levels on and in the vicinity of the nuclear gauge will be performed after a gauge is installed or relocated and prior to use. In particular, radiation surveys shall be performed: Upon initial receipt of the gauge from the manufacturer After installation of the gauge Upon removal of the gauge from a system When the gauge is placed in storage Prior to, during and after any relocation of the gauge

8 Procedure No.: WYN Page: 8 of A radiation survey for analytical x-ray equipment shall be performed upon new installations and thereafter, as necessary, to verify compliance with this standard Prior to using any radiation survey instrument, the following preoperational checks should be performed: Physical Check - Verify that the survey instrument has no debilitating physical defects. Battery Check - Verify the instrument batteries are sufficiently charged to operate the instrument. Calibration Check - The sticker on the side of the instrument should be inspected to ensure that the survey instrument has been calibrated within last 12 months. Meters that have not been calibrated within the last 12 months should not be used for radiation surveys until they have been properly calibrated. Response Check - The survey instrument should be tested for response using the check source located on the side of the instrument. If at any time the instrument does not respond to the check properly, the instrument shall not be used for radiation surveys When performing radiation surveys, the following readings shall be taken and documented: The highest on-contact reading of the gauge and/or component the gauge is installed in. The highest reading at 12" from the gauge or system component the gauge is installed in. The highest general area reading in the vicinity of the gauge. The levels at the perimeter or boundary of any gauge storage area. Levels at any posted radiological boundary or perimeter of the area.

9 Procedure No.: WYN Page: 9 of Radiation levels greater than 10 mrem/hr at any distance greater than 12" from a radioactive source or component should be promptly reported to the RSO Radiation surveys shall be documented on the Nuclear Source Survey and Lockout Form. (See Section 6 Referenced Documents) SURVEY INSTRUMENTS All survey meters on site must be calibrated annually by an authorized calibration and service provider of the manufacturer, in compliance with ANSI N323AB 2013, Instrumentation Test and Calibration- Portable Survey Instruments INSPECTIONS AND LEAK TESTING The RSO shall ensure that a physical inventory of all nuclear gauges is conducted every six months. The inventory will include a review of at least the following items as applicable: The physical condition of the device Adequate radiation caution signs Identification tag on the device The inventory shall be documented and include the following The date of the inventory Location and identification of the devices The quantity and kinds of radioactive material The findings of the physical inspection Each unit shall ensure that all of its nuclear gauges are tested for proper shutter operation every six months. The shutter mechanism must be

10 Procedure No.: WYN Page: 10 of 28 activated and a significant drop in source activity (>80%) must be observed Each unit shall document its shutter testing through an SAP PM work order or other appropriate means The RSO shall ensure that wipe testing is conducted every six months for ECD detectors and every three years for nuclear level gauges as specified in the NRC license. The results will be maintained in the EHS Central Files Nuclear gauges that are in storage do not require shutter testing. Leak testing of stored sources is only required upon removal from storage or every 10 years whichever occurs first All wipe tests should be initially screened for evidence of radiation leakage on the sample using a survey meter prior to sending for analysis. Any positive indications shall result in locking out the leaking device immediately and initiating emergency procedures PROCUREMENT Prior to the purchase of any radioactive materials, including nuclear gauges or x-ray devices, the RSO must be notified, at least, 90 days prior to arrival The RSO shall be responsible for obtaining the necessary license documentation and regulatory agency approval RECEIPT Upon receipt of a radioactive source, and prior to releasing the transporter, the RSO, shall inspect the source package for damage. If the package is damaged, the delivery personnel will be retained until the contamination is assessed.

11 Procedure No.: WYN Page: 11 of The RSO must conduct a survey within 3 hours of receipt (during normal stores hours) and document it using the Nuclear Source Receipt Checklist. (See Section 6 Referenced Documents) If the radiation survey indicates surface contamination or external radiation levels above applicable limits, the RSO shall investigate any possible abnormality and immediately report the incident to the NRC and final delivery carrier company PACKAGE OPENING SAFETY PROCEDURE Wear proper PPE including gloves (nitrile or cotton), safety glasses, and safety shoes Note date and time on the checklist Immediately inspect package for any sign of damage. If damage is present, retain delivery person until contamination assessed Remove the packing slip or other information, if provided on the outside of the package. Verify that the contents are the requested materials Monitor package per regulatory requirements Notify the NRC and final carrier per regulatory requirements if package doesn t meet radiation specifications or the Transportation Index (TI) Open the outer package following any supplied instructions Open the inner package and verify that the contents match the packing slip.

12 Procedure No.: WYN Page: 12 of Check the integrity of the primary container (gauge body, etc) Monitor the external surface of the primary container Monitor the packaging material and the empty package for contamination before discarding. If packaging material is contaminated, segregate it for potential treatment as low-level radioactive waste. If not contaminated, remove or deface all radioactive labels and markings and discard in the regular trash Upon receipt, the following shall be completed: Nuclear Source Receipt Checklist. Verification that the source(s) leak test result(s) are provided with the shipping papers. If the leak test result(s) are not provided, the RSO will contact the manufacturer for the proper documentation. Source(s) shall be placed in a designated, secured storage area. Notification of the respective unit regarding source arrival Once the initial receipt survey is completed, the RSO shall: Generate a master file in the EHS Central Files for each source received. Retain the following documentation for each source in its master file: 1. Shipping papers 2. Sealed Source Device Registry information, if available 3. Initial leak (wipe) test result 4. Nuclear Source Receipt Checklist Update the site s Source Inventory Log.

13 Procedure No.: WYN Page: 13 of STORAGE Devices containing radioactive material shall be stored at a designated secure location within the unit Storage in a secured area is defined as storage in a locked room or building with the purpose of preventing unauthorized removal of the device. The device and the room or building shall be labeled/posted "CAUTION - RADIOACTIVE MATERIAL." A radiation survey must be performed when gauges are placed in storage to ensure that radiation levels at the perimeter of the area do not exceed 2 mrem/hr 4.8. OPERATING PROCEDURES When personnel dosimetry is required, those applicable individuals must: Always wear their assigned thermoluminescent dosimeter (TLD) or film badge when using an x-ray machine and working around or on a level gauge. Only wear the TLD or film badge assigned to them and never wear another person s dosimeter. Never store their TLD or film badge near a radioactive source All applicable individuals must use a gauge or x-ray instrument according to the manufacturer s instructions and recommendations Routine cleaning and maintenance activities shall be performed according to the manufacturer s instructions and recommendations Individuals must ensure that the unshielded source must not be allowed to contact their fingers, hands, or any part of their body.

14 Procedure No.: WYN Page: 14 of Individuals must ensure they never enter the radiation beam during maintenance, repairs, or when working in, on, or around the equipment on which the device is mounted by following the lock-out procedures in Section All nuclear sources and x-ray machines shall be protected from unauthorized access, removal, or use Open beam X-ray devices (i.e. XRF analyzers) must have safety interlocks in place to restrict access while the beam is in operation. The safety interlocks must be tested periodically and the results shall be documented Any X-ray device having an interlock that fails to operate properly shall be immediately removed from service and corrective actions taken to resolve the issue NUCLEAR GAUGE LOCKOUT Only RSO s or authorized individuals may conduct nuclear gauge lockouts. The RSO has designated a list of authorized employees in the units who are trained and qualified to conduct these activities. (See Section 6 Referenced Documents) The nuclear gauge source holder shall be locked out in the "off' or closed position if any of the following occurs: During any manipulation of a density or level gauge, which involves physical movement of the device and/or separation from a pipe or vessel, including installation, relocation or storage; or When individuals are working on or adjacent to a density or level gauge during periods of shutdown; or Prior to removal of a vessel man-way; or

15 Procedure No.: WYN Page: 15 of 28 Prior to an individual entering a vessel in which such a gauge is located (in addition to meeting all other applicable safe work permit requirements) This lockout procedure is applicable only to nuclear gauges. Consult manufacturer instructions for lockout procedures specific to each gauge. The procedure is as follows: Obtain Safe/ Hot Work Permit Locate device to be locked out With the gauge shutter open, place the detector as close to the beam exit surface as possible. This should be your highest contact reading observed. Record reading on the Nuclear Source Survey and Lockout Form or equivalent unit lockout form. Warning: Never place your hands or any other body part in the unguarded beam path. Only expose the tip of the probe, if necessary, keeping hands away from beam path at all times Place detector approximately 1 ft. from the source. Record the reading Close the shutter and retake the readings at the same locations. There should be a significant drop in the radiation field intensity measurements (>80%). This indicates that the shutter mechanism is closed. Record these readings on the form If the shutter cannot be closed properly and leakage is present, DO NOT PROCEED. If it can be closed, then continue to the next step.

16 Procedure No.: WYN Page: 16 of Any readings of >10 mrem/hr indicates leakage of the shutter mechanism. Leakage must be addressed before proceeding with the lockout Secure lock on to the source holder and follow unit procedures for completion of the lockout Complete the form and ensure that the following information is recorded: Gauge information- Model #, Serial #, Vessel #, etc. Monitor information- Model #, Serial #, Cal. Date Meter readings at required locations Sign and date Keep the form with the master tag sheet while the lockout is in process Upon lockout completion, retain the survey form in the departmental records for five years CONFINED SPACE ENTRY PROCEDURE Obtain Confined Space Entry Permit Complete steps through as outlined above Prior to entry, place the survey meter probe inside the vessel in the vicinity where the work will be performed. If the field intensity measurement is <2 mrem/hr., the vessel may be entered by personnel If the field intensity is > 2 mrem/hr., additional source shielding shall be installed to protect personnel performing the entry. Contact the RSO to determine the type, amount and correct placement of shielding.

17 Procedure No.: WYN Page: 17 of In the event that a hazard is created by monitoring the field intensity, or if it is impossible to gather actual field intensity because of the configuration of the confined space, the approximate field intensity may be calculated from the source contact measurement Record reading on the applicable section of Nuclear Gauge Survey and Lockout Form Keep the survey form with the permit while the entry is in progress Upon entry completion, retain a copy of the survey in departmental records for one year. Send the original survey form back to the site RSO All lockouts must be performed according to the Wyandotte Lock, Tag and Try Standard (WYN ) INSTALLATION OF A NUCLEAR GAUGE Installation and initial radiation surveys of devices containing radioactive materials shall only be performed by or under the direct supervision of a Radiation Safety Officer (RSO), or persons specifically authorized by the US NRC to perform such tasks Prior to transport of the device from its storage location, the RSO shall ensure the device is locked out and perform a radiation survey of the source If radiation readings >10 mrem/hr at 12" are observed, further investigation is necessary to determine if there is leakage or contamination present If radiation levels are satisfactory, the RSO shall remove the device from its current storage location and ensure it is properly transported to its service location.

18 Procedure No.: WYN Page: 18 of Install the gauge in a manner consistent with its defined conditions of normal use outlined in the Sealed Source Device Registry information and ensure that it is secured to prevent unauthorized removal Ensure that the unit has the proper labeling visible and the area is posted, as necessary, provided per Prior to returning to routine service, conduct a wipe test for leakage on the gauge using an NLTC Leak Test Kit Unlock the gauge and test for proper operation of the shutter mechanism to verify that it functions as designed Conduct an initial radiation survey of the device. Installations shall be documented on the Nuclear Gauge Survey and Lockout form. The completed form shall be stored with the device s master file until at least three years after the gauge has been transferred or removed from the site and disposed of with a proper licensee During any alignment activities with the gauge prior to returning to routine use, the shutter shall be activated while persons are manipulating the device with their hands. Once the proper alignment has been achieved, the gauge can be activated Install guarding to prevent access to unshielded beam, as necessary Upon completion of installation activities, the site RSO shall update Nuclear Source Inventory Log and file Survey record REMOVAL OF A NUCLEAR GAUGE FROM SERVICE Removal of devices containing radioactive materials shall only be performed by or under the direct supervision of a Radiation Safety Officer (RSO) or persons specifically authorized by the USNRC to perform such tasks.

19 Procedure No.: WYN Page: 19 of All removal activities must be documented on the Nuclear Gauge Survey and Lockout form To remove a nuclear gauge from service and transport from one location to another such as moving to a storage location, the following procedure must be adhered to: Remove all guarding enclosing the gauge, as necessary, to allow for unhindered removal of the unit Secure the device following the Nuclear Gauge Lockout procedure as outlined in Before removing the gauge retaining bolts, ensure that the source is securely strapped and protected against falling or unexpected movements Once the gauge is removed, ensure it is properly labeled, sealed and transported to a controlled and locked storage location. Refer to section 4.7 for storage requirements Upon completion of removal and transfer activities, the site RSO shall update Nuclear Source Inventory Log and file Survey record WASTE MANAGEMENT Licensed materials must be disposed of in accordance with NRC requirements by transfer to an authorized recipient The RSO shall arrange transfer of source ownership to either the original manufacturer or distributor of the device, a commercial firm licensed by the NRC or an Agreement State to accept radioactive waste, or another specific licensee authorized to possess the licensed material (i.e., its license specifically authorizes the same radionuclide, form, and use).

20 Procedure No.: WYN Page: 20 of Before transferring radioactive material, the RSO will verify that the recipient is properly authorized to receive it. In addition, all packages containing radioactive sources must be prepared and shipped in accordance with NRC and DOT regulations INDUSTRIAL RADIOGRAPHY Radiography contractors use x-ray generators and/or sources of gamma radiation to perform radiographic inspection of metal equipment in order to detect flaws in the metal. The areas near a working radiographer are susceptible to scattered radiation. Specific work practices and precautions must be followed by operations and/or other affected personnel because of this source of radiation Precautions must be taken when using industrial radiography in areas that have radiation-type level or density gauges, as this equipment can be affected by the industrial radiography, resulting in process upsets RESPONSIBILITIES OF RADIOGRAPHIC CONTRACTORS Radiography crews shall have, in their possession, an Operating and Emergency Plan, which has been reviewed and updated in accordance with the company's radiation license Radiographers must comply with all applicable regulations per the State of Michigan s Department of Licensing and Regulatory Affairs, Part 6, Industrial Radiographic Operations and Installations, BASF Wyandotte Health and Safety Standards and NRC regulations. All required licenses, procedures, rules, and records must be in the possession of the radiography crew at each job location Each radiographer must have, in their possession, a long-term monitoring device such as a film badge or TLD and a short-term monitoring device such as a pocket dosimeter or pocket chamber.

21 Procedure No.: WYN Page: 21 of 28 One functional, currently calibrated survey meter is also required at each work location Visible placards must be provided on vehicles whenever any radioactive source is present in the vehicle while on the BASF Wyandotte site. External vehicle readings at one foot shall not exceed 2 mrem/hour X-ray machines or radiographic devices must not be left unattended or in unattended unlocked vehicles All accidents or exposure incidents involving radioactive materials or x-ray equipment must be immediately reported to the Unit Management and the RSO WORK PRACTICES FOR RADIOGRAPHERS A boundary at 2 mrem/hr or less shall be determined for all directions and a barricade erected using standard radiographic barricade (yellow and magenta) tape Confirmation of the 2 mrem/hr boundary shall be made with an operable, calibrated survey meter at the time of the first exposure. Special emphasis must be placed on control of the radiation area. Multi-level structures, offices, control rooms, analyzer buildings, roadways, railways and other potentially affected areas must be carefully evaluated by both the radiographer and the permit issuer All modes of access to a radiation area (stairs, ladders, elevators, doors, walkways, roadways, etc.) shall be barricaded and appropriate signs erected Only authorized employees are allowed into the barricaded area.

22 Procedure No.: WYN Page: 22 of Unit Management and Security must approve any work that will require roadways or railways to be blocked The perimeters of all radiography areas must be posted with CAUTION: HIGH RADIATION AREA signs The signs are necessary to provide adequate warning to unauthorized personnel of the high radiation areas and to serve as a reminder to those working with these sources that potentially high levels of radiation exist UNIT RESPONSIBILITIES DURING RADIOGRAPHY The unit must ensure that all personnel working in the immediate area are aware of when and where radiography work is to be conducted The unit must verify that required temporary barriers and signs for radiography work site are in place Unit personnel must never enter an area barricaded by a radiographer The radiographer and assistant(s) are the only personnel authorized to enter the barricaded area. Only in an emergency may a non-radiographer enter a barricaded area and then only after determining that the source has been withdrawn into the camera The job shall be shut down and the safe work permit cancelled if any unauthorized personnel enter the radiography area. The incident must then be reported to the RSO and Unit Management, investigated and deficiencies resolved prior to reissuing a permit to work.

23 Procedure No.: WYN Page: 23 of EMERGENCY PROCEDURES In the event of a fire, explosion or other emergency involving devices containing radioactive materials, the following actions shall be taken: Immediately notify the EHS On Call Phone at (734) and Unit Management. The On Call person will notify both the RSO and alternate RSO. Prevent unnecessary entrance to affected areas until the area has been surveyed. An exclusion distance shall be established for any affected gauge(s) at 10 feet in all directions. (See Section 6 Referenced Documents for calculated distances). Each perimeter shall be appropriately marked as to warn personnel of the radiation hazard. An RSO will survey and inspect the device for radiation levels and physical integrity. In the event radiation levels greater than 100 mrem/hr are encountered, all personnel, including RSO, shall be evacuated from the immediate area until personnel monitoring devices and self-reading dosimeters are obtained and necessary PPE upgrade has occurred. If the device integrity is compromised or if radiation levels greater than 100 mrem/hr are present, efforts shall be made to locate a steel or lead housing in which to place the device or source so that personnel exposures may be reduced. If the gauge is not damaged, the shutter shall be secured in the off or closed position and, if necessary, placed in a controlled storage area. If a gauge has been damaged, the possibility exists that radioactive contamination is present. In that event, personnel access and exit from the affected area will be closely controlled and limited Personnel exiting the area of concern should remove their clothing and seal it in a plastic bag or other sealable container. Proceed to a safety shower and wash the whole body for fifteen minutes.

24 Procedure No.: WYN Page: 24 of Medical attention will be provided to those persons receiving exposure 25,000 mrem or greater, or if the exposure cannot be determined Follow up with medical evaluation if significant exposure is suspected or adverse symptoms develop In the event of an incident involving X-ray producing machines, the RSO must be notified immediately. Corrective actions will be taken and an AIMS report initiated within the next business day. Examples of incidents that must be reported are as follows: A suspected exposure to X-ray radiation. Failure of or damage to the shielding of an X-ray producing device. Note: The instrument shall be locked out and secured so that it cannot be operated until further investigation can be completed NOTIFICATION REQUIREMENTS The RSO shall determine if an incident needs to be reported to the NRC or to the State of Michigan In the event of an incident requiring notification, the RSO will give verbal notification to the NRC Emergency Operations Center at (301) , followed by a written report AUDIT PROGRAM The RSO shall review the content and implementation of site s Radiation Protection Program at least annually to ensure the following:

25 Procedure No.: WYN Page: 25 of 28 Compliance with NRC and State of Michigan regulations and the terms and conditions of the license. Occupational doses and doses to members of the public are ALARA (10 CFR ) The RSO shall document the annual review using the Radiation Program Audit Checklist (See Section 6 Referenced Documents) or other effective means of documentation TRAINING Radiation safety training is not necessary for the site general population due to either the sources being in remote areas or having low radiation levels Personnel designated as Radiation Safety Officers (RSO) shall attend an appropriate radiation safety training course. The course must meet requirements set forth in 10 CFR 30.33(a)(3) RSO refresher training is recommended every five years or sooner, if deficiencies are noted Individuals who routinely work in areas where nuclear gauges are present, perform maintenance or lockouts of nuclear gauges, or work with analytical x-ray machines must receive basic radiation awareness training prior to work with radioactive sources or x-ray producing equipment. The awareness training shall include completion of the Corporate Learning Management System (LMS) Online course- Ionizing Radiation Personnel who routinely perform maintenance or lockouts of nuclear gauges must complete a site-specific nuclear gauge safety training course which shall include the following: Applicable Radiation Regulations and Site Procedures Employee Rights and Responsibilities

26 Procedure No.: WYN Page: 26 of 28 Gauge Design, Use And Maintenance Radiation Survey Instruments And Monitoring Procedures Refresher training for the site-specific nuclear gauge safety course must be completed every three years via either classroom instruction by an RSO or other qualified individual or other effective means Individuals operating and maintaining analytical X-ray equipment must receive safety instructions and demonstrate competence with respect to the following: Identification of radiation hazards associated with the use of the equipment Proper operating procedures for the equipment Proper procedures for reporting an actual or suspected exposure Analytical x-ray users must receive the safety instructions prior to work with the equipment RECORDS Recordkeeping for all radioactive sources shall be set up to provide cradle to grave documentation. A separate file will be maintained for each sealed source. At a minimum, each source should have records of receipt documentation, wipe tests and final disposition. These source files are permanent and shall never be discarded. All program documentation will be kept in the EHS Central Files The RSO will be responsible for maintaining the following documentation for at least five years: Program audit checklists Source inventory Wipe tests results

27 Procedure No.: WYN Page: 27 of 28 Survey documentation Employee exposure records shall be maintained in the EHS Central Files for employment plus 30 years Each unit shall maintain employee training records in the LMS and/or in the individual s unit training file for at least three years Each unit with nuclear gauges shall maintain shutter testing records for each of its sources and lockout survey documentation for at least five years. 5. RESPONSIBILITIES 5.1. EMPLOYEES Responsible for working with radioactive devices and radiation producing equipment safely and for following this procedure as applicable RADIATION SAFETY OFFICER (RSO) Responsible for implementation, maintenance and review of this policy. Responsible for compliance with State of Michigan and NRC regulations, the Wyandotte Site Nuclear Material License provisions and this procedure UNIT MANAGEMENT Responsible for the implementation of this procedure and for compliance of all unit personnel working with radioactive devices or radiation producing equipment with this procedure as applicable.

28 Procedure No.: WYN Page: 28 of REFERENCED DOCUMENTS 6.1. WYN LOCK TAG AND TRY 6.2. RADIATION PROGRAM AUDIT CHECKLIST 6.3. NUCLEAR SOURCE RECEIPT FORM 6.4. LIST OF AUTHORIZED INDIVIDUALS FOR MAINTENANCE AND LOCKOUTS 6.5. NUCLEAR SURVEY LOCKOUT FORM 6.6. EXCLUSION DISTANCES FOR RADIATION SOURCES Note: A 10 foot exclusion distance will be maintained during an emergency with any nuclear gauge as a conservative measure regardless of activity amount. Below are examples of calculated distances. Unit Gauge Type Isotope Activity (mci) Distance (ft) Chem Eng Point Source WFE Gauges (Thermofisher) Cs CEB Point Source Reactor Gauges (KayRay) Cs CEB Point Source Reactor Gauges (KayRay) Cs WYR Point Source Reactor Gauges (Berthold) Cs WYR Line Source WFE Gauges (Berthold) Co