NORM Regulatory Scene

1
NORM Regulatory Scene (an international
perspective) Gert Jonkers Engineering
Analytical - GSEA/4 Problem Solving (Shell EP
Ionising Radiation/NORM HSE Expert
CHP) location Shell Research Technology
Centre, Amsterdam P.O. 38000 NL-1030 BN
Amsterdam the Netherlands
2
EP NORM What to Monitor?
3
COLLOQUIAL TERMINOLOGY for NORM
LSA maximum NOR-concentrations (15,000
Bq226Raeq/g 2,000 Bq210Pbeq/g and 2,800
Bq228Raeq/g), are in a range classified as Low
Specific Activity (LSA) material by the
International Atomic Energy Agency (IAEA)
transport regulations. Terms like LSA scale,
LSA sludge or even LSA contamination are in
vogue. NOR Naturally Occurring Radionuclides
(NORs) the element (K, U) is naturally
occurring, while some or all of its isotopes
(0.012 40K 99.276 238U, 0.004 234U and 0.720
235U) are unstable and decay emitting ionising
radiation (radioactive). NORM Materials or
substances that do contain NORs as a minor
component or contaminant. As most natural
resources do contain NORs (average
concentrations in the Earth's crust 4.2 ppmU
or 0.05 Bq238U/g, 12 ppmTh or 0.05
Bq232Th/g) all these may termed NORM, no matter
how low the NOR-concentrations are.
4
(REGULATORY) DEFINITION NORM TENORM

• NORM - Naturally Occurring Radioactive Material
• Natural radioactivity material in its natural
  state, such as in geological formations or soils,
  in which human activities have not taken place to
  enhance the concentration of NORM e.g. rocks,
  soils, background radiation. Human activities
  involving NORM may enhance radiation exposure
  pathways through redistribution (e.g. bringing
  subsurface NORM to the surface). NORM may be
  subjected to a national Atomic Energy Act.
• TENORM - Technologically Enhanced NORM
• TENORM is NORM (not subject to Atomic Energy
  Acts) disturbed or altered from natural
  settings, or present in a technologically
  enhanced state due to human activities, which
  may result in a relative increase in radiation
  exposures and doses to the public above
  background radiation levels. Here,
  technologically enhanced implies that the
  physical, chemical, radiological properties, and
  NOR-concentrations have been altered in such a
  way that there exists a potential for
• redistribution and contamination of environmental
  media (soil, water, and air)
• increased environmental mobility in soils and
  groundwater
• incorporation of elevated concentrations in
  product and waste streams,
• NOR-contamination of (internal) equipment or
  installation surfaces, and
• improper disposal or use of disposal methods that
  could result in unnecessary and relatively high
  exposures to individuals and populations via any
  environmental pathway and medium.

TENORM encountered in the gas/oil industry will
be denoted by EP NORM
5
EP NORM History
1918 Radioactivity of the Natural Gases
(Satterly et al.) 1928 Radioactivity Oil
Fields (Tscherepennikov et al.) 50s US USSR
Oil Field Screening as a potential resource for
Uranium (interest disappeared, when it turned out
that the levels of radioactivity were due to
enhanced levels of NORs of radium). 70s EP
NORM rediscovered from a Health Safety
Environment point of view. Natural Gamma logging
Tool (i.a applied for Clay typing, Mineralogy
Geochemistry, Depth correlations) records log
anomalies due to radioactive scales deposited
near the perforation in production tubing. Making
an (in-house) inventory of the NORM
issue. 80s Extending the NORM issue inventory.
90s Struggle to implement the non-nuclear
TENORM HSE issue under Basic Safety Standards
6
1
1928 Radium Commission (International Society of
Radiology) with time widened from protection in
medical radiology to all aspects of protection
against ionising radiation 1959 New publication
series started
Publication 1 Recommendations of the
ICRP 1964 Publication 6 Recommendations of the
ICRP 1966 Publication 9 Recommendations of the
ICRP 1977 Publication 26 Recommendations of the
ICRP 1978-87 Amendment Statements at various
Meetings 1991 Publication 60 Recommendations of
the ICRP
. 2005 Publication 100? (draft) Recommendations
of the ICRP
The ICRP has always been an advisory body
offering its recommendations to regulatory and
advisory agencies at international, regional, and
national levels, mainly by providing guidance on
the fundamental principles on which appropriate
radiological protection can be based. The ICRP
does not aim to provide regulatory texts.
Authorities need to develop their own texts in
the context of their own regulatory structures.
Nevertheless, the ICRP believes that these
regulatory texts should be developed from, and
have aims that are broadly consistent with, its
guidance.
7
2
JUSTIFICATION 1 No practice involving radiation
shall be adopted unless its introduction produces
a positive net benefit. ALARA (also known as
ALARP) 2 All radiation exposures shall be kept as
low as reasonably achievable, economic and social
factors being taken into account.
DOSE LIMITS 3 The radiation dose to individuals
shall not exceed the limits recommend for the
appropriate circumstances by the Commission.
Radiation Worker (special medical controls, dose
monitoring, etc.) 20,000 ?Sv/a
Members of the public (incl. non-radiation
workforce) 1,000 ?Sv/y
World-Wide (population) averaged Natural
Background Dose 2,400 mSv/y
8
3

• Drawbacks 1990 Recommendations
• ? EP NORM is not an on purpose application of
  Ionising Radiation source (practice), so
  Justification principle cannot be applied. At the
  most a generic justification (for EP NORM
  encounter) may the economic and social benefits
  stemming for gas/oil production.
• ? No specific guidance is provided on EP NORM
  (large LSA volumes of LLW versus small HSA
  volumes HLW of artificial radionuclides)
• NORM may be the focus of nuclear industrial
  activities (e.g. uranium ore extraction) or
• TENORM may be a burden for non-nuclear
  industries (e.g. gas/oil production EP NORM,
  ore extraction and gas/oil/ore processing)

• Awaited issue of ICRP 1990 Recommendations
• Drafts of harmonised IAEA Basic Safety Standards
  and the European Council 96/29/Euratom Basic
  Safety Standards used for defining exemption
  levels
• TENORM addressed in section 7. Technologically
  Enhanced Natural Radiation (TENR)
• The wide scope (Shell Group still owned a metals
  division ore extraction and processing) was not
  always helpful

9
Late 80s/Early 90s EP NORM Regulations
United States due to disagreement between
federal bodies (EPA, NRC) and state departments
responsible for gas/oil industry HSE, several
gas/oil producing states issued own EP NORM
Regulations. The Conference of Radiation Control
Program Directors (CRCPD) tries to harmonise
these regulations by issuing a NORM Regulations
template (part N). Malaysian Federation issued
very stringent EP NORM Regulations. By issuing
release concentrations below background
NOR-concentrations all waste disposal activities
more or less become prohibited. Canada Western
Canadian NORM Committee (joint initiative of
industry and province governments) issued fairly
detailed guidelines and exempt concentrations for
environmental media (air, water, soil) derived
from IAEA exempt limits. European Community
member states do have very distinct opinions on
EP NOR-concentrations as national legislation
based on European Council 84/467/Euratom
Directive state a release concentration of
500 Bq/g, where the SI-unit Bq is described as
total Bq leaving ample space for interpretation.
10
1996 IAEA Basic Safety Standards EP NORM

• IAEA Basic Safety Standards (BSS)
• ? Implementation of the ICRP 1990
  Recommendations.
• ? Strong focus to on-purpose application of
  ionising radiation sources (practices).
• Issuing exempt radionuclide-specific total and
  concentration limits, which have been derived
  from enveloping on-purpose scenarios
  referenced against a dose criterion of 10
  mSvindividual/y and 1 manSvcollective/y.
• ? Regulatory and HSE definitions for NORs, e.g.
  226Raeq means 226Ra in secular equilibrium with
  its short-lived progeny up until 214Po.
• NOR-exempt limits lead to confusion as NOR exempt
  limits issued were meant for NORs applied in
  on-purpose radiation sources (so these exempt
  limits are not applicable for EP NORM exempt
  limits)
• ? Harmonisation with the European Council
  96/29/Euratom Directive
• N.B. The IAEA is an intergovernmental
  organisation (est. 1957) under the auspices of
  the United Nations (UN). It provides a forum for
  scientific and technical co-operation in nuclear
  practices and is the international inspectorate
  for the application of nuclear safeguards and
  verification measures covering non-defence
  nuclear programs. One of the IAEAs statutory
  objectives is to establish radiation protection
  standards.

IAEA BSS jointly sponsored by the FAO (Food and
Agriculture Organisation of the United Nations),
IAEA (International Atomic Energy Agency), ILO
(International Labour Organisation), NEA(OECD)
(Nuclear Energy Agency of the Organisation for
Economic Co-operation and Development), PAHO (Pan
American Health Organisation and WHO (World
Health Organisation)..
11
1996 96/29/Euratom Directive EP NORM

• European Council 96/29/Euratom Directive Basic
  Safety Standards (BSS)
• ? Implementation of the ICRP 1990
  Recommendations.
• ? Strong focus to on-purpose application of
  ionising radiation sources (practices), but
  Title VII addresses Significant Increases in
  Exposure to Natural Radiation Sources (work
  activities) requiring more or less that member
  states have inventories made on the extent of the
  industrial NORM issue.
• Issuing exempt radionuclide-specific total and
  concentration limits, which have been derived
  from on-purpose enveloping scenarios
  referenced against a dose criterion of 10
  mSvindividual/y and 1 manSvcollective/y.
• ? Regulatory and HSE definitions for NORs, e.g.
  226Raeq means 226Ra in secular equilibrium with
  its short-lived progeny up until 214Po.
• NOR-exempt limits lead to confusion as NOR exempt
  limits issued were meant for NORs applied in
  on-purpose radiation sources (so these exempt
  limits are not applicable for EP NORM exempt
  limits)
• ? Harmonisation with the IAEA Basic Safety
  Standards.

12
96/29/Euratom Guidance EP NORM

• Work Activities (EP NORM)
• Expert Group (Article 31 of the Euratom Treaty)
  Recommendations
• ?    for NORM the benefit of their use and
  processing (referring to its association with the
  economical and social importance of gas/oil
  production) outweighs the radiation detriment,
  and that it is sufficient to put a constraint on
  individual dose
• ?   as a result of the large volumes of material
  processed and released by NORM industries, the
  concept of exemption and clearance merge, and
  it is appropriate to lay down a single set of
  levels both for exemption and clearance, and
• while the basic concept and criteria for
  exemption/clearance for work activities are
  very similar to those for practices, it is not
  meaningful to define the levels on the basis of
  the individual dose criterion for practices (10
  µSv/y) instead a dose increment, in addition to
  background exposure from natural radiation
  sources of the order of 300 µSv/y is appropriate.
  
• Radiation Protection 122 part II Practical Use
  of the Concepts or Clearance and Exemption -
  Application of the Concepts of Exemption and
  Clearance to Natural Radiation Sources (2002)

13
ESTABLISHMENT OF GENERAL EXEMPT LIMITS
RISK
Likelihood of Fatal Cancer
Source Dose Constraint to be endorsed by the
Competent Authority
DOSE
Forward Calculation - Applied for Deriving
Unconditional Release (Exempt) Limits or for
Determining Compliance with Dose or Risk
Standards
Effective Dose in Sievert
EXPOSURE
Derived Limits to be endorsed by the Competent
Authority for any circumstance (Unconditional)
External Internal
CONCENTRATION (air, water, soil)
Becquerel per m3, L or g
14
European Union Recommended Exempt Limits
Regulatory Terminology General Clearance
Level General Exempt Level gtgt Unconditional
Release Limit ltlt
15
Late 90s till now EP NORM Regulations
United States still quarrelling between EPA and
state departments who sits in the driving seat
to regulate NORM (How far should a risk- based
approach in view of the natural background
radiation dose be pushed. Latest CRCPD draft
part N 1999. Malaysian 1996 skipped formerly
issued release concentrations for solids.
Especially for scale and sludge disposal a
Radiological Impact Assessment demonstrating
compliance with the ICRP public dose limit is
required. Canada 2000 previous guidelines
reviewed and reissued nation-wide. Unconditional
Release Limits derived from enveloping
total-dose assessment scenarios provided for
environmental media (air, water, soil). NORM dose
constraint set at 300 mSv/y. Allowance for
Conditional Release Limits by having carried out
dedicated total-dose assessment scenarios.
European Union 2000 implementation of EC
Directive 96/29/Euratom and accompanying guidance
documents did not (yet) achieve full
harmonisation for member state EP NORM
regulations. Middle East several gas/oil
producing states (Egypt, Oman, Syria, UAE) start
to issue national EP NORM Regulations.
16
NORM Source Constraints Unconditional Release
Limit
17
2005 draft Recommendations
18
EP Global HSE Standards and Procedures(Integrated
in the EP MS Future 2004)
Yellow guides
Group Ionising Radiation Protection Guide
2005 Yellow Part shall statements
and incorporating the 2005 ICRP
Recommendations Accompanied by two additional,
fairly detailed documents on NORM Practices
Applied in all assets departments in EP plus a
local layer if required for any country
regulationand local risk requirements