HEALTH AND SAFETY PROGRAM 406 IONIZING/NONIONIZING RADIATION PROTECTION

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1 Page 1 of PURPOSE Axiall, Plaquemine Complex, maintains various sources of ionizing and nonionizing radiation throughout the complex. Ionizing radiation sources include density gauges and PMI Analyzers. Nonionizing or electromagnetic frequency (EMF) radiation sources include microwave ovens, video display terminals (VDT's), and any other device with the potential to emit EMF. It is Axiall's, Plaquemine Complex, policy to ensure that sources are functioning properly, employees are trained and knowledgeable concerning source safety, appropriate monitoring is conducted, and the absorbed dose for any employee is maintained well below accepted limits. 2.0 SCOPE This program applies to all Axiall, Plaquemine Complex, employees who order, use, work in proximity to, handle or receive radioactive sources and radiation producing devices subject to State license or registration. These items include density gauges, PMI Analyzers and industrial radiography equipment. 3.0 DEFINITIONS Absorbed Dose--The amount of absorbed energy per gram of tissue. ALARA--(acronym for "as low as is reasonably achievable") means making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest. Cesium ( 137 Cs)--The radioisotope of cesium, an alkali metal. 137 Cs is a beta and gamma emitter with a half-life of approximately 30 years. If entered into the body it is absorbed through the gastrointestinal tract and distributed throughout the whole body. Curie (Ci)--A measure of the rate at which a radioactive material emits particles. One curie equals 3.7 x disintegrations per second. Half-Life--The time it takes for an amount of a radioactive nuclide to decay to one-half of its original activity.

2 Page 2 of 11 Ionizing Radiation--Includes alpha particles, beta rays, gamma rays, X-rays, neutrons, high-speed electrons, high-speed protons, and other atomic particles that produce sufficient electron volts necessary to ionize water molecules. Ionizing radiation does not include sound, radio frequency, electromagnetic radiation, visible light, infrared or ultraviolet light. Licensee--The Axiall, Plaquemine Complex, proprietor of the Louisiana Division of Radiation Control radiation license. The licensee is the Radiation Safety Officer and site Industrial Hygiene Manager. Nonionizing Radiation--Electromagnetic energy which contains photon energies well below the ten to twelve electron volts necessary to ionize water molecules. Nonionizing radiation is considered to include electric energy, radio frequency radiation, microwave radiation, infrared, and ultraviolet light. rem--a unit of dose measurement of any ionizing radiation energy to body tissue in terms of its estimated biological effect equivalent to a dose of one roentgen (r) from X- rays. The relation of the rem to other dose units depends upon the biological effect and the type of irradiation. Each of the following is considered to be equivalent to a dose of 1 rem: 1. A dose of one roentgen due to X or gamma radiation; 2. A dose of one rad from X, gamma, or beta ray radiation; 3. A dose of 0.1 rad due to neutrons or high-energy protons; or 4. A dose of 0.05 rad from particles heavier than protons and with sufficient energy to reach the lens of the eye. Source--A device, instrument, or piece of equipment that has the potential to emit ionizing or nonionizing radiation. 4.0 RESPONSIBILITIES 4.1 Health and Safety (H&S) Conduct initial Hazard Communication Safety Orientation training which includes Ionizing/Nonionizing Radiation Protection Program information Train employees annually on the requirements of the Ionizing/Nonionizing Radiation Protection Program.

3 Page 3 of Originate and maintain monitoring/measuring records in a legible, identifiable, and retrievable form for at least 30 years. (See Axiall, Plaquemine Complex, HSP Employee Workplace Monitoring and Medical Surveillance Program) Notify contractors of Axiall's, Plaquemine Complex, Ionizing/Nonionizing Radiation Protection Program Ensure that the Ionizing/Nonionizing Radiation Protection Program is audited at least every three years Maintain audit records in a legible, identifiable, and retrievable form Audit contractor compliance with the Ionizing/Nonionizing Radiation Protection Program requirements at least every three years. 4.2 Department Supervision: Learn, understand, and follow Axiall's, Plaquemine Complex, Ionizing/Nonionizing Radiation Protection Program Ensure that each employee and contractor, in their work area, complies with Ionizing/Nonionizing Radiation Protection Program requirements Notify H&S and the Licensee of any suspected damage to a source in their work area. 4.3 Licensee: Maintain the Louisiana Division of Radiation Control License, No. LA L01, according to all license requirements Amend the license to reflect any changes in personnel, source locations, source changes, or new source additions Maintain a recordkeeping system in accordance with all license requirements including a listing of radioisotope results from radiation surveys and leakage testing Conduct an annual inspection of sources and source installations to ensure compliance with license requirements.

4 Page 4 of Train, test, and observe work practices of technicians performing surveys and inspections which are necessary to comply with license requirements. 4.4 I/E Supervision: Conduct ionizing radiation surveys prior to work by Axiall or contractor personnel on equipment or vessels utilizing radioactive sources In the event of suspected damage to a source, I/E Supervision will: 1. Perform a survey to determine if ionizing radiation levels are above or below 5 millirem (mr) per hour; 2. Secure the area against personnel entry; 3. Secure all process equipment capable of spreading contamination; and 4. Notify H&S and the Licensee. In the absence of the Licensee, the Louisiana Division of Radiological Services ( ) will be notified immediately Ensure that all monitoring and measuring devices for ionizing radiation are calibrated according to manufacturer's specifications Maintain instrument calibration records in a legible, identifiable, and retrievable form. 4.5 Employees Learn, understand, and follow Axiall's, Plaquemine Complex, Ionizing/Nonionizing Radiation Protection Program Report any suspected source damage to their supervision. 4.6 Contractors: Learn, understand, and follow Axiall's, Plaquemine Complex, Ionizing/Nonionizing Radiation Protection Program Allow H&S to audit their compliance with the Ionizing/Nonionizing Radiation Protection Program at least every three years.

5 Page 5 of PROCEDURE 5.1 Ionizing Radiation There are currently a total of three (3) ionizing radiation sources located at the Axiall Plaquemine Complex. All three sources contain 137 Cs and are located within the Caustic Chlorine Unit. All sources are maintained so that the nearest accessible surface activity level is well below 5 mr/hr As Low As Reasonably Achievable (ALARA) Philosophy The radiation safety program at Axiall's, Plaquemine Complex fully supports the concept that all radiation doses should be ALARA. This implies that no dose should be acceptable if it can be avoided or is without benefit. Our ALARA program depends on the cooperation of all users of radionuclides and their supervisors at Axiall s, Plaquemine Complex Source Locations: Location Type Source Strength mci CC Salt Slurry Flow to Centrifuge 137 Cs 20 First Effect Slurry Line 137 Cs 200 CC Liquid Chlorine Receiver 137 Cs Posting and Labeling: 1. Appropriate signs are posted at entrances to source areas so that personnel are aware of the presence of radioactive materials, whether or not there is an exposure potential. 2. Each device or source containing radioactive material is labeled with a "Caution: Radioactive Material" sign AND a label which identifies the radioisotope, its activity, and the date of measurement or reference as per 10 CFR and 10 CFR

6 Page 6 of Monitoring and Measuring Surveys: 1. A radiation survey will be performed with a calibrated radiation monitoring device prior to work conducted by Axiall or contract personnel on equipment or vessels utilizing radioactive sources. 2. If measurements taken during the survey exceed 5 mr/hr in the work area, the H&S Department and the RSO will be contacted and consulted before work begins. 2. Written results from all surveys will be provided to the Licensee. The form found in Appendix A may be used to provide written results of surveys. 3. The Licensee will ensure that an outside contractor is retained to perform wipe tests and conduct periodic maintenance as required, at least every three years. 4. The Licensee will maintain documented results of contractor testing and maintenance. 5. Personal monitoring is not required during normal operations. 6. All monitoring and measuring equipment will be maintained and calibrated according to manufacturer's specifications Radioactive Materials Storage: 1. Devices containing radioactive sources may be temporarily stored in any normally unoccupied and secured location within the complex provided that: a. The source is secured or locked within the device; b. The device is appropriately labeled; c. The area is secured and locked to prevent unauthorized removal of the device; and d. The area is posted with a "Caution - Radioactive Material" sign. 2. The Licensee must be informed when a device is placed into and removed from storage.

7 Page 7 of Permission for Entry: 1. All personnel must obtain permission from the Licensee before entering any vessel or enclosure that may utilize a radioactive source. 2. I/E Supervision will ensure that a source is tagged and locked in its shielded position until the work inside the vessel or enclosure is completed. 3. A radiation survey will be performed on any source prior to work on equipment or vessels utilizing any sources (see 5.4.1). 4. Contractors (radiographers, etc.) must contact the Licensee prior to bringing a radioactive source into the complex Emergencies: 1. The Licensee and H&S will be notified immediately of any suspected damage to a source within the complex. 2. An immediate notification is required to the U.S. Nuclear Regulatory Commission (NRC) at (301) upon any event involving a radiation source possessed by Axiall, Plaquemine Complex that may have caused or threatens to cause any of the following conditions -- a. An individual to receive -- (i) A total effective dose equivalent of 25 rems (0.25 Sv) or more; or (ii) A lens dose equivalent of 75 rems (0.75 Sv) or more; or (iii) A shallow-dose equivalent to the skin or extremities of 250 rads (2.5 Gy) or more; or b. The release of radioactive material, inside or outside of a restricted area, so that, had an individual been present for 24 hours, the individual could have received an intake five times the annual limit on intake.

8 Page 8 of A twenty-four hour notification is required to the U.S. NRC at (301) upon any event involving a radiation source possessed by Axiall, Plaquemine Complex that may have caused or threatens to cause any of the following conditions a. An individual to receive, in a period of 24 hours -- (i). A total effective dose equivalent exceeding 5 rems (0.05 Sv); or (ii). A lens dose equivalent exceeding 15 rems (0.15 Sv); or (iii) A shallow-dose equivalent to the skin or extremities exceeding 50 rems (0.5 Sv); or b. The release of radioactive material, inside or outside of a restricted area, so that, had an individual been present for 24 hours, the individual could have received an intake in excess of one occupational annual limit on intake. 4. Whenever there is damage, fire, theft, loss or other unusual occurrence affecting a nuclear gauge or sealed source immediate notification to the Louisiana Department of Environmental Quality Registrations and Certifications section at (225) shall be made. 5. The Licensee, I/E Supervision, and H&S will be notified immediately so that a physical radiation survey can be conducted; and 6. Personnel will be restricted from entering the area, except in a lifesaving situation, until the radiation survey is complete and it is determined that it is safe to enter. 7. Axiall's, Plaquemine Complex, emergency response procedures will be put into effect and appropriate governmental organizations notified of the emergency. 5.2 Nonionizing Radiation Various sources of nonionizing radiation are located throughout Axiall's Plaquemine Complex. Microwave ovens are the primary source of nonionizing radiation.

9 Page 9 of TRAINING Microwave Ovens: Microwave ovens are located in lunch and breakrooms throughout the complex for employee convenience. They are only to be used for cooking and heating of food. 1. Employees are required to maintain microwave ovens in a clean, sanitary condition. 2. Only nonmetallic items should ever be placed into a microwave oven. 3. Do not attempt to operate a microwave if: a. An object is caught in the door; b. If the door does not close properly; or c. If there is any damage to the door, hinge, latch, or sealing surface. 4. Any microwave oven, which is damaged or not operating properly, must be removed from service and disposed of as industrial waste. 5. All entrances to an area containing a microwave oven will be posted with a sign stating "Microwave Oven in Use." 6.1 H&S provides employees awareness level training for ionizing/nonionizing radiation during initial Hazard Communication Orientation Training. 6.2 The Licensee conducts specific ionizing radiation safety training to all technicians who may conduct inspections or measurement surveys on radioactive sources. 7.0 RECORDKEEPING 7.1 The Licensee maintains all records for ionizing radiation sources in accordance with Louisiana Division of Radiation Control requirements. 7.2 Any measurement of personnel exposure to ionizing radiation will be maintained in employee medical records for the duration of employment plus 30 years (refer to Axiall's, Plaquemine Complex, Employee Workplace Monitoring and Medical Records Program).

10 Page 10 of The Health and Safety Department maintains calibration records for all ionizing measurement instruments. 8.0 AUDITS 8.1 H&S will ensure that an audit of the Ionizing/Nonionizing Radiation Protection Program is conducted periodically to ensure continued program effectiveness. 8.2 The audit will include: The current Ionizing/Nonionizing Radiation Protection Program; Employee training records; Records required by the Louisiana Division of Radiation Control; Employee awareness; and Contractor awareness. 8.3 Following the audit, the Ionizing/Nonionizing Radiation Protection Program will be revised to include any necessary changes. 8.4 Audit results will be documented. 8.5 All employees will be informed of any changes made to the program. 9.0 REFERENCES American Conference of Governmental Industrial Hygienists ( ). "Threshold Limit Values for Chemical Substances and Physical Agents." American Industrial Hygiene Association (2010). "Nonionizing Radiation Guide Series, Radio Frequency and Microwave Radiation." Baron, David (1991). "Measuring EMF Emissions from Video Display Terminals." Reprinted from Compliance Engineering Magazine. National Safety Council (1988). "Fundamentals of Industrial Hygiene," Third Edition. Edited by Barbara A. Plog. Occupational Safety and Health Administration's 29 CFR (1996). "Ionizing Radiation." Occupational Safety and Health Administration's 29 CFR (1996). "Nonionizing Radiation."

11 Page 11 of 11 Nuclear Regulatory Commission s 10 CFR 19 (1973) Notices, Instructions, and Reports to Workers; Inspections. Nuclear Regulatory Commission s 10 CFR 20 (1991) Standards for Protection Against Radiation APPENDICES Appendix A - Ionizing Radiation Emitter Survey Data Sheet.

12 Appendix A Ionizing Radiation Emitter Survey Data Sheet

13 IONIZING RADIATION EMITTER SURVEY DATA SHEET Location: Floor: Room: Date: Process Detail: Operations Detail: Source: Manufacturer: Type: Serial No.: SAMPLE LOCATION SKETCH: Instrument: Check Source: Surface (area)(distance): Wipe (area): In 2 Other: Other: Lab Results: Calculations: Calibration Date: Calibration Date: Scale Reading: Scale Reading: Scale Reading: Scale Reading: x x x x