AL FURAT PETROLEUM CO. NORM MANAGEMENT SYSTEM

1. AL FURAT PETROLEUM CO.NORM MANAGEMENT SYSTEM

2. Leadership and commitment HSE Policy Statement: AFPC conducts its activities in such a way as to protect the health and safety of its employees and other persons, and to safeguard the conservation of the natural environment. AFPC Management believes that: • Working conditions should not damage the health of its staff, or third parties and the environment • Accidents are preventable • HSE conservation are of equal importance to other business objectives • HSE conservation are corporate responsibilities discharged through line management

3. AFPC NORM Objectives • Implementation of suitable PPE • Implement clean up efforts using a cost/benefit approach • Prevent spread of radioactive substances in the environment • Treat,store and dispose of contaminated equipment and radioactive waste in a controlled manner

4. NORM PolicyStatement AFPC will: ·      Protect its personnel, contractors, 3rd parties and the environment against the hazards of exposure to ionising radiation due to AFPC activities. ·      Avoid uncontrolled releases of radioactive contaminated substances and to minimize the effects of past deposits ·      Apply the principles of ICRP 60 for radiation protection (justification of a practice, optimization of protection and dose & risk limitation) • No new practices shall be adopted without justification that they are of benefit •    Keep exposure As Low As is Reasonably Practicable (ALARP) where exposure to ionising radiation is not avoidable •    Prevent any exposure to ionising radiation levels that result in an effective dose of more than 1 mSv/y above background to non-classified personnel and to the public Avoid the need for classified radiological workers wherever reasonably practicable

5. Organisation Four organizational entities advise on Ionising Radiation: -   The Senior Radiation Protection Supervisor (SRPS) -  The Radiation Protection Supervisor (RPS) -  The Radiation Protection Technician (RPT).

6. Hazards and effects managements • Evaluate radiological data • Identify risk-reducing measures • Set realistic objectives and performance criteria • Identify credible emergency events and identify response requirements and plans

7. SRPS Responsibilities: • Be current on all potential and actual NORM-related activities within the company at all times • Ensure records/registers are kept on radiological workers, Ionising Radiation sources, NORM measurements (count and dose rates, specific activity), radioactive waste, and radioactive contaminated equipment •   Identify the number of RPSs and RPTs required •   Audit implementation of the NORM management system

8. RPS Responsibilities : • Inspect and give radiological assistance in supervision of work involving ionising radiation sources of a non-routine nature •   Ensure quality assurance of radiation protection • Organize the required monitoring and sampling • Qualify waste with respect to radioactivity • Ensure that radioactive waste and NORM-contaminated equipment is stored, packaged, transported and disposed off in compliance with regulations and procedures • Communicate with and report to the SRPS

9. RPT Responsibilities : • Measure count rates whenever no data are available on installation parts to be opened • Register and report the results in compliance with the relevant NORM Procedure • Notify the RPS if count rates exceed the agreed standards

10. NORM Training AFPC have a suite of courses dedicated to NORM. The line shall develop and maintain a training database specifying requirements per job. This includes training requirements for Contractors. NORM course synopsis • Radiation awareness Course • NORM Course for Supervisors • Radiation Protection Technician (RPT) Course

11. Hazards of NORM External hazards It is AFPC policy to keep the external radiation dose below 1 mSv/y above background. This is achieved by controlling exposure due to specific measures such as limiting exposure time, restricting access to high radiation areas, etc. The main contributor to external dose is Gamma radiation. Like X-rays, Gamma radiation can penetrate through steel and the whole body

12. Hazards of NORM Internal hazards The principle hazard of exposure to NORM is associated with absorption of radioactive particles into the body by ingestion or inhalation or through cuts in the skin. The reason that this is hazardous is due to the nature of Alpha and Beta particles being highly charged. Thus, if they are allowed to come into contact with sensitive cells, the Alpha and Beta particles will be absorbed and will cause continuous damage to them.Simple controls can prevent the risks from cuts and ingestion. This leaves inhalation as the main hazard.

13. NORM Measurement Flowchart Is equipment/location known or suspected to have NORM /LSA activity LSA not possible Yes No NORM precautions External Radiation Gamma radiation> 1μSv/hr at working position Yes Inform RPS if γ > 2.5μSv/h Inform SRPS if γ> 7.5μSv/h No Active procedure to control Gamma exposure Yes NO Alpha/Beta Contamination, α> 2 cps or β >15cps Inform RPS if γ> 1μSv/h But no α / β detected Yes Full NORM / LSA precautions Inform RPS if “hot work” or, if “vessel entry”

14. Items or waste contaminated with NORM shall not be stored or despatched, unmarked or without appropriate documentation. The material shall be correctly sealed, packaged, labelled, transported and stored according to the procedure. As explained, the priority with NORM scale handling is to stop dust being inhaled. This is achieved by adhering to procedures which: ·                    Stop dust being created ·                    Stop dust entering the body ·                    Contain scale in one area These procedures are generally based on: ·                    Minimizing work on scaled equipment ·                    Wearing respiratory protection and other PPE ·                    Barricade work areas, restrict access and contain waste Handling of NORM

15. Packing, temporary storage and transport Items or waste contaminated with NORM shall not be stored or despatched, unmarked or without appropriate documentation. The material shall be correctly sealed, packaged, labelled, transported and stored according to the procedure.

16. Clean up of NORM contaminated area To provide radiological advice on practical implementation. Management shall ensure the availability of a detailed programme including budget, resource and standards requirements for effective implementation • A detailed execution plan • Proposed clean up criteria • Special measures

17. Due to the source strengths of isotopes within AFPC the most likely emergency scenarios are: - Unexpected exposure to ionising radiation sources - Trespassing the designated area -    Loss or any other unaccounted absence of ionising radiation sources -   Transport accident Emergency procedures

18. Emergency procedures Line management shall ensure emergency procedures are followed. Where a contractor does the radiation work. These shall include the prescribed protective equipment (e.g. shielding materials, remote handling equipment) and all corrective actions. In addition to the urgent corrective actions, AFPC management and the SRPS shall be informed immediately to estimate exposure consequences and to plan additional actions.

19. It is AFPC’s policy to keep exposure to employees below 1 mSv above background per year wherever reasonably practicable (ALARP). As a consequence there should be no one classified as radiological worker and if so no dose registration is obligatory. Also no medical surveillance and record keeping is necessary. Contractors should keep their own registers. Register of radiological workers

20. Personal radiation dose records For re-assurance purposes dosimeters will be used on a selective basis and results will be entered in an SRPS controlled database. In addition, this database will contain dose estimates calculated from work records. These will be made available on request. For exposure control NORM dose estimates shall be made using dose rate and exposure time data.

21. Decontamination The NORM decontamination Plant is used to remove NORM scales from equipment in order to prepare it for re-use or safe disposal. Operational controls to prevent the spread of contamination are specified whenever work on contaminated equipment takes place.

22. Sources are used by Contractors on behalf of AFPC to carry out activities such as radiography and well logging. Such tasks involve the use of highly radioactive sources and X-ray equipment which if misused can lead to high dose uptake to both contractors and AFPC personnel Records must be kept of all ionising radiation sources on Company premises. Their exact location should be known at any time (logbook). The SRPS will specify the data to be kept. Contractors shall keep their own registers and ensure that as a minimum the AFPC requirements will be kept. Control of Radiological Sources used on AFPC operations

23. Derived limits Routine and non-routine jobs on NORM contaminated installations Protection of personnel against NORM risks Carrying out, recording and interpreting NORM surveys Supervised and Controlled Areas Sampling for NORM Packing, temporary storage and transport Decontamination of personnel NORM measuring programme Radiological safety precautions for wireline jobs Radiological safety precautions for dismantling flanges Radiological safety precautions for NORM contaminated filters Radiological safety precautions for NORM contaminated vessels and tanks Radiological safety precautions for pigging operations Radiological safety precautions for the workshop Clean up of NORM contaminated areas Control, issue and care of Radiation Protection Instrumentation Dose assessment Decontamination of equipment Control of contaminated equipment NORM training Radiological safety precautions for well re-entry Control of Radiological Sources used on AFPC operations AFPC NORM Manual CONTENT:

24. NORM Yard inventory NORM contaminated scale