Naturally Occurring Radioactive Material (NORM) Supersedes: 05/30/08 (Rev.01) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

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1 Procedure No.: PA Page: 1 of 8 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Changed Header and Footer VB 05/08 Procedure Reviewed (No Changes) TF 11/08 Modified the Purpose statement, step 2.1, 2.10, 2.11, 4.1.2, TAD 09/ , 4.2.3, 4.2.4, 4.3.4, 4.3.5, 4.4.1, 4.4.2, 4.5.2, 4.5.3, 4.5.7, and Added steps 2.2, 2.3, 2.4, 2.5, 2.7, 2.12, 4.1.1, and Added note under step Deleted step Reviewed no changes. DS 03/2016

2 Procedure No.: PA Page: 2 of 8 1. PURPOSE This procedure establishes the minimum guidelines for opening, entering, maintaining, cleaning, storing, and/or disposing of equipment potentially contaminated with Naturally Occurring Radioactive Material (NORM). This procedure designates safe work practices to minimize personnel exposures from NORM. 2. DEFINITIONS 2.1. Action Level Alpha and/or Beta 5000 disintegration s per minute (DPM) or 500 counts per minute (CPM), corrected for background. Gamma 2 millirems/hr or 2000 microrems/hour, corrected for background ALARA As Low As Reasonably Achievable Making every reasonable effort to maintain exposures to radiation as far below the regulated dose limits as is practical. Three typical methods are Time, Distance and Shielding Background Radiation The radiation constantly present in the natural environment of the Earth, which is emitted by natural and artificial sources Counts per Minute (CPM) The number of atoms that are detected to have decayed in one minute Corrected Counts per Minute (CCPM) Counts per Minute minus the background counts per minute Decontamination The physical or chemical removal of NORM from the surface of structures, work areas, equipment, or material to the Action Level Disintegration s per Minute (DPM) The number of atoms in a given quantity of radioactive material that decay in one minute. CPM times the detector efficiency equals DPM Line and Equipment Opening The physical opening or first break of a chemical line, vessel or piece of equipment.

3 Procedure No.: PA Page: 3 of 8 2. DEFINITIONS cont d 2.9. NORM Naturally Occurring Radioactive Material, belonging to the radon decay scheme including the decay products polonium and lead NORM Contaminated Equipment Equipment or material that contains NORM contamination in excess of: 5000 DPM (500 CPM) on fixed equipment using a meter; or 1000 DPM (100 CPM) removable, using wipe test; or DPM (1500 CPM) at any point on the equipment using a meter. NORM contaminated equipment cannot leave the site unless it has a removable wipe test reading of less than 1000 DPM (100 CPM) NORM Equipment Process piping and equipment that has potential to contain NORM in excess of the action level Roentgen Equivalent Man (REM) A unit for measuring radiation levels. Measures potential biological damage to the body tissue as a result of exposure to radiation. Typically expressed as (milli) mr/hr or (micro) µr/hr RSO Radiation Safety Officer charged with control and implementation of procedures for the safe handling of NORM and other sources of ionizing radiation Regulated Work Area An area established to exclude unauthorized personnel from entry during maintenance tasks involving disturbance of NORM containing scale. 3. SCOPE This procedure applies to all BASF and contract employees at the Port Arthur site who are required to work in or around equipment that is potentially contaminated with NORM.

4 Procedure No.: PA Page: 4 of 8 4. PROCEDURE 4.1. Identifying NORM Equipment Routine external surveys should be performed in areas where NORM is suspected. This is to characterize the workplace conditions and assess hazards A historical database for NORM levels will be established, identified and maintained by the EHS Department All process piping and equipment that has the potential to contain NORM activity in excess of the action level will be identified as NORM Equipment Potential NORM piping/equipment will be identified by painting perimeter lines and posting signs in those areas. NOTE: Areas in the Port Arthur site that will be considered potential NORM piping and equipment until proven otherwise will be: The entire propylene refrigeration system, including C4, T3101 bottoms, T2601, S2601A/B, T4001 bottoms, T4501 tower, R4601A/B, T4701, T4801, T6301, D4803 and all interconnecting piping, exchangers, pumps, and equipment Evaluating NORM Equipment The EHS Department Representative will assess potential NORM exposures and determine PPE required for initial opening Equipment which is identified as in a NORM potential service, see step , will not be opened until radiation levels measured on the external surface of the equipment, with the model 44-2 Gamma Scintillator detector, are below 2000 micro rems/hour During initial opening, NORM equipment will be tested internally for NORM contaminants with the Model 44-9 pancake detector to determine if the equipment is contaminated (see step 2.10) An EHS Representative shall be present during the initial opening.

5 Procedure No.: PA Page: 5 of 8 4. PROCEDURE cont d Opening NORM Equipment Barricades shall be established at sufficient perimeters during potential NORM equipment opening When feasible, equipment having a potential for NORM should have a sufficient lapse time (approximately four hours) to allow NORM levels to decay appropriately. Purging of equipment may be performed during the lapse time Opening NORM Equipment cont d Slip blinds may be installed during the lapse time Chemical or leather gloves, Tyvek suit with hood, rubber boots, safety goggles and a full face respirator equipped with a NIOSH P100 Cartridge shall be the minimum PPE required for the initial line breaking. If NORM levels are elevated, additional PPE may be required to perform the initial line-break Classification of NORM Contaminated Equipment When an evaluation of NORM equipment or material, indicate results above the action level, that item will be classified as NORM Contaminated NORM contaminated PPE, tools etc. shall be handled in accordance with Section Maintenance of NORM Contaminated Equipment NORM contaminated equipment will be handled in a manner to minimize potential exposures to NORM and avoid contaminating other work areas NORM contaminated equipment shall be covered, wrapped, or otherwise secured. Items to large to be wrapped should be transferred to a designated temporary control storage area.

6 Procedure No.: PA Page: 6 of 8 4. PROCEDURE cont d. 4.5 Maintenance of NORM Contaminated Equipment cont d Welding, cutting and grinding shall not be performed on NORM contaminated equipment until proper decontamination of the equipment has been conducted. Only the area to be cut or welded requires decontamination procedures. If decontamination is not possible, respiratory protection will be utilized by welders Significant disturbance of contaminated NORM equipment such as, but not limited to, grinding, sanding, scraping, buffing, or cutting shall require designating a regulated work area Regulated work areas shall be designed by red barricade tape and signs posted on all sides of the barricade Immediate work surfaces subject to potential contamination shall be covered with 6 mil polyethylene Prior to exiting a regulated work area, personnel, PPE, tools and other equipment shall be tested for contamination. If NORM is detected above 2 times background, the item or person must be decontaminated and retested An evaluation of potentally contaminated work areas shall be performed to ensure decontamination prior to de-regulating any NORM work areas Contaminated coverings shall be placed in an appropriately labeled drum Equipment sent off-site for repairs or disposal shall be evaluated for the presence of NORM. Any equipment contaminated with NORM above 1000 DPM (100 CPM) cannot leave the site and shall be decontaminated Labeling, Storage, Transport and Disposal of NORM Equipment/materials A NORM storage area shall be designated and clearly marked Only NORM contaminated materials shall be stored in the Norm designated area and shall not be stored longer than 90 days.

7 Procedure No.: PA Page: 7 of 8 4. PROCEDURE cont d. 4.6 Labeling, Storage, Transport and Disposal of NORM Equipment/materials cont d Equipment classified as NORM-Contaminated shall be stored and maintained in the designated area The RSO shall designate authorized entrants into the NORM regulated area for entry, material storage and/or material removal All contaminated materials shall be clearly marked NORM contaminated with an approved radiation tag, date and time, highest detectable reading and the name of the surveyor Disposable parts classified as NORM contaminated shall be placed in NORM labeled drums or individually wrapped in 6 mil polyethylene and stored in the NORM storage area until shipment Chemical decontamination of NORM contaminated equipment shall be performed by a licensed firm Release for shipment or unrestricted disposal shall be authorized by the RSO The RSO shall approve decontamination procedures The RSO shall verify evaluations of decontamination Waste drums and other equipment shall be clearly labeled with DOT Specifications as per 49 CFR Training All personnel who have the potential for exposure to NORM during the performance of their duties shall receive NORM awareness training every 2 years. This training will include:

8 Procedure No.: PA Page: 8 of 8 4. PROCEDURE cont d. 4.7 Training cont d Potential health hazards of NORM exposures Proper work practices Minimizing exposures and work place contamination. Personal Protective Equipment Procedure requirements Operations of NORM testing equipment Monitoring methods Sample handling Labeling 5 RESPONSIBILITIES 5.6 Port Arthur Leadership Team Has primary responsibility for implementation of this procedure. 5.7 EHS Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure. 5.8 Port Arthur Employees Has primary responsibility for adherence to procedure including identifying deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with the procedure. 6 RELATED DOCUMENTS PA Respiratory Protection