Document o5pjozKaYw3XvQap0d9jjXq8

SECTION 12 RADIATION PROG SECTION 12: RADIATION PROGRAM A detailed description of the division Radiation Program is provided in the LAD Safety Standard S307. Other sources of reference for radiation safety are the Safety and Loss Prevention Manual for Contractors, NRC 10 CFR 150, and Louisiana DEQ regulation (LAC:33 part XV). The Louisiana Division Radiation Program is administered by the Radiation Safety Officer (RSO), Henry Hopper who is located in building 4103 extension 1877. The RSO will have direct control over any radiation producing device. He must be present for the following tasks: receiving, transporting, installation, removal, and relocation of any radioactive material or device The RSO will be notified prior to any relocation of the device and will be present during relocation. Classifications: Radiation-containing or radiation-producing devices within the Louisiana Division fall into three distinct categories: sealed sources, radiation machinery, and naturally occurring radioactive materials (NORM). Sealed sources may include: level indicators, densitometers, radiographic exposure devices, and lab analyzers. The X-Ray machine used by medical and the certified cabinet x-ray systems are considered radiation machines. Also, NORM is present in some process equipment located in LHC 2. Training: Personnel in blocks which have radiation-containing or radiation-producing devices are required to have training commensurate with the level of hazard prior to use. The levels of training may vary from the minimum of HAZCOM training on the hazards of radioactive material to a high level of training for those designated personnel who are trained and licensed as radiation safety officers. A list of trained personnel should.be documented (Appendix B) and maintained in this section. Inventory: An inventory of all radiation-containing or radiation-producing devices in the facility must be documented (Appendix A) and stored in this section-. This inventory must include the Dow Tag No., isotope, activity, and location. A plot plan showing location of the device(s) is recommended. Radiation Warning Signs: All sealed sources must have signs posted on or near the device stating "Caution: Radioactive Material". In addition, other signs concerning vessel entry and line openings must be posted as required by the radiation regulations (e.g. warning signs by vessel manways). These signs are available through the RSO. 11-2-92 12.1 oo A 044??? CONFTO Inspection performed bv the RSO: An installation survey is performed prior to placing a radiation producing device into service. Thereafter, an annual inspection is performed during the first quarter which includes: an inventory check, the physical location, visual inspection of labels and signs, shutter operation testing, and general condition. Wipe testing of sealed sources is performed by the RSO (or trained designee) in accordance with NRC guidelines (i.e. frequency is dependent on the type of nuclide), if the removable activity is >0.005 microcuries (indicating a leaking source), the LAD Industrial Hygiene Department will be contacted. Radiation survey meters are calibrated annually with the exception of those used for compliance with the NORM regulation which are calibrated semiannually. Personnel Monitoring: Monitoring must be provided for employees who service sealed sources where the whole body dose rate may exceed 5 mR/hr and for personnel performing maintenance on NORM containing equipment. Emergency Procedures: The plant/department must have a written procedure for notifying security and notifying affected personnel during an emergency involving radioactive materials. Any situation which may compromise the integrity of the containment device such as, fire or explosion is considered an emergency. Plant Security and Radiation Safety Committee Members also have a detailed procedure for dealing with emergencies involving radioactivity. This section contains the following documents: 1. Plant/Department Specific Radiation Program Each plant/department containing radioactive sources is required to have: a) An inventory (Appendix A), b) A list of trained personnel (Appendix B), c) In-plant procedures which describe safe handling practices, d) Vessel entry and/or line entry procedures, and e) Emergency notification procedures. C,D, and E are usually located in plant procedure manuals or on the computer. Where these procedures are located shall be noted in this section. 11-2-92 DO 12.2 cONf Tr)FNTlAL 1803 BUILDING December 10,1993 Tht Dow Chemical Company Midland, Michigan 48674 RESTRICTED FOR USE WITHIN DOW AND SUBSIDIARIES ADDRESSED Distribution List on Reverse side cc: G. E. Socha, DowElanco, Indianapolis P. J. Lachmann, MMD, Cinncinati G. J. Urbanski, MMD Kansas City PRENATAL RADIATION PROTECTION POUCY The new Title 10 of the Code of Federal Regulations Part 20 addresses Standards for Protection Against Radiation. Prenatal radiation protection is described in section 20.1208 and states that a pregnant radiation worker must be protected so that the dose to the embryo/fetus during the gestation period does not exceed 0.5 rem. This protection can be offered provided the employee chooses to declare their pregnancy in writing to their employer. To comply with this new standard which becomes effective on January 1, 1994, Dow has developed a process for the implementation of the prenatal radiation protection policy. This flow diagram is attached along with a checklist which can be used to serve as documentation for the policy. A copy of this checklist will be forwarded to the Medical department and filed with the employee's medical records, while the original should be filed with the employee's radiation safety dosimetry records. Please inform all employees authorized to work with radioisotopes and or radiation producing machines, of this policy and make additional copies as needed. If you have any questions please contact Eva Crim at (517) 636-1440. S. L. Dombrowski Chairman Radiation Safety Committee E. M. Crim Radiation Safety Officer PROCESS FOR THE IMPLEMENTATION OF THE PRENATAL RRDIRTION POLICY FOR EMPLOYEES AUTHORIZED TO WORK WITH RROIORCTIUE MRTERIRLS RND/OR IONIZING RRDIRTION PRODUCING DEUICES RRDIRTION TRRINING PROUIDED TO EMPLOYEES BY INDUSTRIAL HYGIENE I EMPLOYEE HRS CONCERNS REGRRDING UJORK WITH RRDIORCTIUE MRTERIRLS/RRDIRTION RROIORCTIUE MRTERIRLS/OR RRDIRTION *Rs per NRC 10 CFR 20.1208 and 20.2106 RADIATION SAFETY MEETING CHECKLIST PRE-NATAL RADIATION PROTECTION This meeting between_______________ and IH/Rad.safety Employee name Name on19__________ is being held to review and discuss pre-natal radiation protection. To comply with Title 10 of the Code of Federal Regulations Part 20.1208: I,have chosen to declare to my employer The Dow Employee name Chemical Company that I am pregnant. I understand that the Dow radiation protection policy strives to maintain all radiation exposures/ as low as reasonably achievable. However, as an approved radioisotope user or authorized operator of radiation producing equipment, I am requesting additional protection, as applicable, for maintaining my radiation dose to 0.5 rem during the term of my pregnancy for which the date of conception is estimated to be _ (month! (year!. I,also agree to inform my employer. Employee name The Dow Chemical Company, in the event I am no longer pregnant. This notification is necessary to comply with the appropriate exposure limit which for a non-pregnant radiation worker is 5 rem/year. * + * * * * * * * * * * % * * * * * * * + * * * + * * * * * * * * * * * * * * * * * * * * ** * * * * * * # * * * * * * # * * * * * *** A copy of the Regulatory guide 8.13 "Instructions concerning prenatal radiation exposure" has been provided. Initial Date The regulatory requirements outlined in 10 CFR 20, "Standards for Protection Against Radiation" regarding occupational radiation exposure and the radiation dose to the embryo/fetus have been reviewed and discussed Dow Confidential Initial Date ^0 A 044226 confidfnttal EmC 12/93 My job activities involving radioactive material and/or radiation producing equipment have been reviewed and discussed. Radiation safety has made the following recommendations regarding radiation protection measures: A copy of this checklist will be forwarded to Dow Medical for record keeping purposes. Employee Signature Date IH/Radiation Safety Signature Date Dow Confidential DO A 044227 CONFIDENTIAL EmC 12/93