Management of Naturally Occurring Radioactive Material

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Procedure for Management of Naturally Occurring Radioactive Materials

Procedure for Management of Naturally Occurring Radioactive Materials

ROO-ALL-HS-PRO-0109 Pictures are for illustration purposes only

Revision history
Revision number 01 02 03 Date 16/05/12 12/06/12 17/07/12 Brief description of change For client review and adjustment Client changes Client changes Prepared RC Checked RS RS RS Approved JL Rumaila approval

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Table of contents
1.0 Summary ................................................................................................................................. 4 2.0 Introduction ............................................................................................................................ 4 2.1 Intent and purpose ................................................................................................................... 4 2.2 Application................................................................................................................................ 4 2.3 References, abbreviations and definitions ............................................................................... 4 3.0 Responsibilities...................................................................................................................... 5 3.1 Site Controller .......................................................................................................................... 5 3.2 Area Authority .......................................................................................................................... 5 3.3 Safety Advisor .......................................................................................................................... 5 3.4 Performing Authority ................................................................................................................ 6 3.5 Work party ................................................................................................................................ 6 4.0 Naturally occurring radioactive material ............................................................................. 7 4.1 Naturally occurring radioactive material - general ................................................................... 7 4.2 Naturally occurring radioactive material - exposure and hazards ............................................ 8 4.3 Naturally occurring radioactive material (NORM) contaminated waste ................................... 9 4.4 Naturally occurring radioactive material flowpath .................................................................. 11 4.5 Naturally occurring radioactive material local rules ............................................................... 12 4.6 NORM storage ....................................................................................................................... 14 4.7 NORM contaminated equipment............................................................................................ 15 4.8 NORM decontamination ......................................................................................................... 15 5.0 Personal Protective Equipment .......................................................................................... 18 5.1 Personal Protective Equipment - general .............................................................................. 18 5.2 Radiation barrier tape and signs ............................................................................................ 19 Appendix 1 - Training, competence and authorisation ............................................................................. 20 Appendix 2 - Compliance and auditing ....................................................................................................... 21

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1.0 Summary
The crude oil produced at Rumaila facilities may contain a by-product of naturally occurring radioactive material. Uncontrolled activities associated with enhanced levels of naturally occurring radioactive material can contaminate the environment and pose a risk to personnel at the site. These risks can be alleviated by the adoption of the controls described in this procedure. All personnel must work in compliance with this procedure which is part of the HSE Management system.

2.0 Introduction
2.1 Intent and purpose
The intent of this procedure is to define the responsibilities of Rumaila personnel and their contracted service companies when working with and disposing of naturally occurring radioactive material (NORM). The purpose of this guide is to define how to control, store and safely dispose of solid and liquid wastes produced which contain naturally occurring radioactive material. The goal is to prevent oilfield worker exposure from inhalation and ingestion of NORM dust or particulate, and to help ensure that NORMcontaminated equipment is not sent out for repair, released for use or sold as scrap metal with the potential to expose subsequent handlers or the public.

2.2

Application

The scope of this procedure is to ensure that work with naturally occurring radioactive material is carried out safely and that specific measures will be taken to comply with statutory controls affecting: Work involving the processing, handling, use, holding, storage, transport, or disposal of naturally occurring radioactive material The preparation of contingency plans to deal with accidents or incidents

This procedure is applicable to all Rumaila personnel involved with naturally occurring radioactive material at any Rumaila facility.

2.3

References, abbreviations and definitions

2.3.1 Related documents

The following documents are related to the NORM procedure and you should refer to each document as necessary. Document number ROO-ALL-HS-PRO-0001 ROO-ALL-HS-PRO-0010 Title of procedure Control of Work Manual Confined Space Entry

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2.3.2 Abbreviations
The following abbreviations are used in this document. Acronym AA CoW HSE HITRA PA PPE PVC SA Area Authority Control of Work Health Safety Environment Hazard Identification and Task Risk Assessment Performing Authority Personal Protective Equipment Polyvinyl Chloride Safety Advisor Explanation

3.0 Responsibilities
3.1 Site Controller
The Site Controller has overall responsibility for the health and safety of personnel at each site. The Site Controller is also responsible for ensuring that all precautions and controls are implemented at his site when any work involving naturally occurring radioactive material is being carried out. (see Appendix 1 - Training, competence and authorisation)

3.2

Area Authority

The Area Authority (AA) is responsible for the area where naturally occurring radioactive material is located. The Area Authority will ensure that all barriers are erected and measures are implemented to reduce the risks to as low as reasonably practicable (ALARP). He is also responsible for: Ensuring the naturally occurring radioactive material area is clear of all non-essential personnel Ensuring toolbox talk is conducted prior to work start Ensuring that all precautions stated on the Permit are implemented Ensuring that all personnel possess and use the required Personal Protective Equipment (PPE) and that it is in a serviceable condition

3.3

Safety Advisor

The Safety Advisor (SA) shall assist the Area Authority (AA) and Site Controller in ensuring that all precautions stated on the Permit are implemented. The Safety Advisor (SA) is responsible for: Monitoring of the work area Ensuring that safe working practices are being enforced at all times

(see Appendix 2 - Compliance and auditing)

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3.4 Performing Authority
The Performing Authority (PA) is the person actually carrying out the work or leading the work party. Performing Authorities are accountable for the safety of themselves, their work party and anyone impacted by their work. Performing Authorities are responsible for: Being fully conversant with the work, the potential hazards and associated precautions Carrying out the safe execution of assigned work Briefing (toolbox talk) everyone in the work party in the potential hazards, precautions and conditions applicable to the work Ensuring everyone concerned understands the task, the hazards and the precautions especially where the work party is multi-lingual Ensuring the Permit, HITRA and any other associated documentation is displayed at the work site, wherever practicable

3.5

Work party

A member of the work party is anyone who carries out work under the direction of the Performing Authority. They are responsible for: Signing the Permit to acknowledge that they have received and understood a suitable toolbox talk Reporting all worksite problems immediately to the Performing Authority (PA) Working under the terms and conditions specified for safe work when working with naturally occurring radioactive material Alerting the Performing Authority on identifying where the conditions specified in the Permit cannot be complied with

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4.0 Naturally occurring radioactive material

4.1 Naturally occurring radioactive material - general
Naturally occurring radioactive material is a natural component of our environment which is found in geological formations (Figure 1). It is usually brought to the surface in produced water. As the water approaches the surface, temperature and pressure change causes radioactive elements to precipitate out of the liquid phase and form solids. Resulting scale and sludge may collect in piping and vessels in crude or water separation systems. Radium is usually found in this type of naturally occurring radioactive material contamination. Gas Sphere Crude Oil Tank Produced Water Tank

Gas Oil Separator

NORM in Scale

NORM in Gas NORM in Crude Oil

Figure 1: The origins of naturally occurring radioactive material

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Naturally occurring radioactive material also occurs in gas processing where radon gas brought to the surface enters the gas production stream. As it decays, thin radioactive films may form on the inner surfaces of gas processing equipment (Figure 2). SCALE DEPOSITED IN A SALTWATER FLOWLINE

Figure 2: Example of NORM contamination

4.2

Naturally occurring radioactive material - exposure and hazards

Radium 226 and Radium 228 are the principal radioisotopes associated with oil and gas fluids. These elements and daughter decay products emit alpha, gamma and beta radiation. The most serious health hazard is the alpha radiation. Alpha particles consist of two protons and two neutrons (essentially a helium nucleus without the electrons of a helium atom) with a charge of plus 2, and an atomic weight of 4, emitted in the decay of heavy elements. These tiny charged cannon balls do not travel far but do serious damage to living cells they pass through (Figure 3). Human exposure may occur when contaminated dusts and sludge are inhaled or ingested (internal exposure) or when gamma radiation from surrounding equipment strikes the body (external exposure). When scale containing alpha emitters dries and becomes airborne as dust, alpha emitting particles can be inhaled deeply into the lungs of people in the area. Alpha radiation released in lung tissue can cause serious damage. Gamma and beta radiation also released by NORM scale are relatively weak and present a much lower radiation hazard.

Gamma Gamma

Alpha Beta

Gamma Gamma

Gamma

Figure 3: Naturally occurring radioactive materials exposure scenarios

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4.2.1 Potential long-term health effects
Unprotected overexposure to radium and radium daughter contaminated dusts has been associated with an increased risk of lung cancer and leukaemia. Most naturally occurring radioactive material taken into the body is deposited in bones where it will reside for a long time. Radium will not clear from the body significantly over time. For this reason, all exposures should be kept below recognised exposure standards and unnecessary exposure to radiation should be minimised.

4.3

Naturally occurring radioactive material (NORM) contaminated waste

If any naturally occuring radioactiove material is suspected, contact the Rumaila Environmental team to obtain additional information and allow for the further evaluation of the material to determine if it is NORM and, if necessary, how to handle and dispose of the waste. Naturally occurring radioactive contaminated materials exceeding 70 Becquerels per gram (70 Bq/gm) are subject to: UN recommendations on the transport of dangerous goods requirement International Maritime Dangerous Goods Code International Air Transport Association Dangerous Goods Regulations

Naturally occurring radioactive material contaminated wastes may include filters from contaminated process streams, storage and transport tank scale or sludge, water separation tank sludge and well bore scale. Naturally occurring radioactive material storage areas shall be separated from other materials and entry restricted. The storage area requires periodic radiation surveys to ensure gamma levels are not increasing above hazardous levels and/or site contamination is not occurring from leaking containers. Production tubing contaminated with radioactive material scale shall be capped, labelled and stored. Pulling of well tubes should be performed to ensure that any sludge contained within is radioactive material free. Other wastes should be barrelled, preferably plastic to prevent corrosion, labelled and stored. Naturally occurring radioactive material contaminated wellhead tubing and equipment require special handling procedures. After pulling the xmas tree and wellhead equipment: Blind flange all piping ends to ensure that any radioactive material scale does not fall out Install closed end thread protectors on each end of pipe and tubular assembly pieces

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The pipe and equipment must remain with ends secured until they are transferred to a protected cleaning area. The pipe and equipment must be labelled according to its level of activity when transporting.

NORM monitoring required

Instrument/survey procedure

Record survey results

Report survey results

Trained personnel available?

YES

Select appropriate detectors

Instruments in calibration functioning?

YES

Obtain work permits

NO

NO

Train personnel or contact trained personnel

Send for repair/calibration

Carry out background check

Training record

Return instruments to storage for re-use

NO

Carry out survey

Instrument calibration records

YES

Instruments Instruments in incalibration calibration functioning? functioning?

Inform of survey findings

Normal Operations

Controlled Hazard

Safe disposal options

Documentation

Figure 4: Schematic of surveying for naturally occurring radioactive materials

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4.4 Naturally occurring radioactive material flowpath
The following flowpath (Figure 5) determines the actions to be taken if there is a potential risk of radiation exposure.
Is there the potential for exposure to radiation? Yes No End

Carry out initial radiation check on breaking of containment and before any work begins. Use dosemeter & measure in Sv/hr (microsieverts/hour)

Reading is less than 7.5 Sv/hr?

No

Controlled Area Consult with Rumaila Radiation protection Supervisors

Yes

Proceed with work, complying with Permit

Yes

Reading is less than 3.0 Sv/hr?

No

End

Is total estimated exposure greater than 1 mSv/year (1 millisievert/year) (dose x time)

Unsure

Consult with Rumaila Radiation protection Supervisors

Yes Supervised area

Comply with the management of norm local rules (see page 12)

Figure 5: Naturally occurring radioactive material flowpath

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Table 1 dose readings correspondence to allowed minimum exposure time per day per worker. Dose rates will fall off rapidly with distance (using barriers and signs) and effective shielding (for example, high mass materials and graphite). Dose readings (Sv/hour) 3.5 4 5 6 7.5 Maximum allowed exposure time (min/day) 130 115 90 75 60

Table 1: Dose readings

Note:

For non-classifed workers (annual exposure < 1mSv)

4.5

Naturally occurring radioactive material local rules

The following are the operational steps which are to be taken for the safe management of naturally occurring radioactive material, which includes background measuring naturally occurring radioactive material levels. Personnel and equipment contamination checks before, during and after work involving naturally occurring radioactive material is carried out (Figure 6). The implementation and control of this process is the responsibility of the Rumaila Environment team and Site Controller at each site. The Rumaila Control of Work (CoW) manual is to be referenced in conjunction with this procedure. Any work which requires or may involve personnel coming into contact with naturally occurring radioactive material is to be planned and include a HITRA before the work commences Agree with the site where the work is to be carried out that there will be no simultaneous operations that may affect or impact the safe working distance/controlled area for the naturally occurring radioactive material work Prior to the work commencing the toolbox talk checklist is completed with the team assigned to complete the work. Only approved workers are permitted to work with naturally occurring radioactive material. This will include the barrier equipment and the following PPE:o Tyvek style coveralls o Neoprene, Polyvinyl Chloride (PVC) or nitrile rubber gloves o Half-face respirators with high-efficiency particulate air cartridges. These should be tested for fit o Quarter-face high efficiency particulate air disposable respirators o During the work no personnel are permitted to eat or drink within the work area. Drinking and eating can only happen once the worker has been checked for contamination and the personal protective equipment removed, bagged and sealed for disposal. Hygiene is very important with the washing of hands and face being mandatory Confined spaces and vessel entry procedures, equipment are to be used at all times Only personnel who have dose badges are to handle the naturally occurring radioactive material for both removal from vessels or other areas, and including transportation for disposal to the approved disposal site Prior to work commencing a background check is required around the vessel to confirm radiation levels. This information has to be included in the Permit The radiation meters are to be checked and calibrated against a test source

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Prepare the work area by barriering off the area with a suitable distance, 360 degrees around the vessel Prior to opening inspection hatches or sludge traps, sufficient ground cover shall be placed below the item in the work area. The ground cover should be made of a plastic, waterproof type of material capable of withstanding the work activities involved without tearing or ripping. Alternatively, a suitable drip-tray or catch-pan may be used. The ground cover should be sized to provide for the contamination of leakage and waste and to allow ample room for related peripheral work Signs in English are to be attached to the barrier stating:Danger NO ENTRY - Naturally occurring radioactive materials (NORM) The barrier is to have a Sentry present to prevent unauthorised personnel from entering the area for the entire duration of the work Take samples from the vessel, via the drain valves, before opening the access flange to establish possible radiation levels inside the vessel If the samples taken indicate a possible high reading within the vessel, then the vessel should be cleaned via steam. It is important that any waste fluid or solids are collected in suitable sealed containers and handled by the approved workers for disposal Any dry material that is naturally occurring radioactive material which has been contaminated should be wetted down to prevent the generation of airborne radioactive materials. Dry material should be wetted periodically throughout the maintenance work Repeat the sampling process after cleaning of the vessel until such time as the radiation reading reaches the acceptable level A reading is taken from within the vessel to confirm the radiation is low. Until this is confirmed no personnel are permitted to enter or work on the vessel from the outside Openings of equipment or pipes that have internal naturally occurring radioactive material contamination should be sealed or wrapped by plastic or other suitable materials All the approved workers are to be checked to confirm that their personal protective equipment fits correctly and is used. The workers are checked for contamination during/after working with the naturally occurring radioactive material and after carrying out cleaning and washing of their hands and face Obsolete naturally occurring radioactive material, contaminated pipes or equipment should be clearly labelled as naturally occurring radioactive material contaminated materials and removed to a designated storage area. The area should be labelled as containing radioactive materials and restricted from the general public All contaminated waste generated during maintenance should be drummed or put into containers and marked or labelled. Representative samples should be collected from the waste and analysed for radioactivity Once the work has been completed and the area is confirmed as being cleared of naturally occurring radioactive material, the naturally occurring radioactive material waste and equipment is bagged and sealed along with contaminated personal protective equipment. The waste is to be removed from the site by the approved team Disposal has to be confirmed by a certificate, stamped and signed by the Site Controller and naturally occurring radioactive material team leader Upon completion of the work the Permit is signed off as complete; the site has been left in a safe condition with post work radiation levels being recorded on the Permit IF AT ANY TIME THE ABOVE STEPS ARE NOT FOLLOWED, THEN ALL WORK MUST STOP UNTIL THEY ARE IMPLEMENTED.

Note:

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Extraction fan

Entrance Ground Cover Ground Cover Special Drain Washing facility and towels Used PPE Exit New PPE

Figure 6: Naturally occurring radioactive material contamination site control

4.6

NORM storage

Where naturally occurring radioactive material waste is required to be stored at a Rumaila facility, it shall be kept in a suitable container which shall comply with the following requirements. The container: Shall be in a good condition with no visible indications of internal or external corrosion Be made of a durable material that provides adequate containment of the waste during the storage period Shall be made of, or lined with, materials that will not react with or be incompatible with the waste so that the ability of the container is not impaired or compromised Shall be resistant to degradation by ultra violet radiation Shall be closed and sealed during storage, and practical to open and re-seal when it is necessary to add or remove waste Shall not be opened, handled or stored in a manner that may rupture the container or cause it to leak Shall bear the radiation symbol and a label clearly indicating that it contains contaminated waste Shall be resistant to normally expected range of temperature in storage environment Shall be resistant to water ingress Shall be stored in a dry environment to prevent corrosion Shall be physically robust to prevent damage during transport The storage location should be hard surfaced and bunded to prevent contamination of ground/surface water and the creation of contaminated land from any potential leaks/spills as a result of incidents during storage period

Areas where containers of naturally occurring radioactive material waste are stored should be inspected on a regular basis. Containers should be inspected for signs of leakage, overall deterioration and proper labelling. Records of these inspections should be documented and properly maintained.

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Where naturally occurring radioactive material waste is disposed of, records shall be maintained of the disposal activities. They should include but are not limited to: Waste material description; for example, scale, sludge and scrapings Volume of waste material Mass Naturally occurring radioactive material level (activity per unit weight) of waste material Methods of disposal Disposal location Organisation/facility where the naturally occurring radioactive material waste was generated Any other relevant information

4.7

NORM contaminated equipment

The following are the minimum requirements for the control of NORM contaminated equipment at a Rumaila facility. Equipment shall: Be decontaminated prior to release for unrestricted use Be stored only in designated storage areas Be tagged or clearly marked as contaminated Be handled only by employees trained in naturally occurring radioactive material hazards and wearing relevant protective personal equipment Not to be sent for maintenance/repair to Rumaila workshops without informing the workshop that the component is contaminated with naturally occurring radioactive material Be disposed of only in an approved disposal facility Be decontaminated only in an approved decontamination facility or according to an approved decontamination protocol Be stored in areas which are exclusively used for the storage of contaminated equipment

4.8

NORM decontamination

Decontamination of equipment which is naturally occurring radioactive material which is contaminated should be undertaken in a controlled manner to ensure worker protection, prevent the spread of contamination, and to minimise the waste arising from the decontamination process. High pressure water jetting may be used for decontamination. When high pressure water jetting is used, the following are to be supplied: Changing facilities for workers Operating areas to carry out the work Handling/receiving areas Strip down areas Water jetting areas Ventilation system Inspection of equipment Monitoring of equipment

A mobile decontamination unit may be used. These utilise modified containers to provide containment for high pressure water jetting operations, and are fitted with drainage systems which direct water used in the operation through a series of filters and back to the water jetting system, so the waste is continually recirculated.

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The following are the types of portable areas that may be required at a Rumaila facility in the event of naturally occurring radioactive material contamination.

4.8.1 Handling area

This will be for: Checking the inventory/material being sent for decontamination Carrying out radiation surveys of decontaminated equipment Providing a segregation system to keep incoming dirty items separate from outgoing clean items A quarantine area for items that require further decontamination

4.8.2 Strip down area

To allow components such as valves and wellheads to be stripped down.

1.1.1.1 Pressurised habitat enabling oxy-propane cutting and grinding of equipment

This is an area where airborne naturally occurring radioactive material contamination may occur and therefore requires total containment with a filtered extract ventilation system. Workers will be required to wear respiratory protective equipment in this area.

1.1.1.2 Water jetting area

This is an area where airborne naturally occurring radioactive material contamination may occur and therefore requires total containment with a filtered extract ventilation system. In this area workers will be required to wear respiratory protective equipment. The floor and surfaces should be capable of withstanding the impact of high pressure water jetting.

1.1.1.3 Liquid recirculation system

All process liquid used in decontamination operations should be filtered and re-used. There should be no connection to any external drainage system. The following three elements will be required in the system: Primary supply tank Filter bank Settling tank

The system needs to separate naturally occurring radioactive material contaminated sediment and oily waste material from the process water. Water from the jet area will be circulated back to the system by an enclosed and doubly contained drainage system. A leak detection system should be included in the water circulation system. The settling tank should be able to be readily accessible and able to have any sediment removed/decanted into waste containers. The system shall have capacity to allow the transfer of water from the settling tank to another holding tank to allow sediment removal.

1.1.1.4 Control of equipment

An administrative system is required to control and track the progress of all equipment and components entering the decontamination facility. Inspection of all equipment and components should be carried out on receipt. The status of the equipment should be logged and any damage not logged on the documentation should immediately be brought to the proponents attention. The component shall be quarantined pending further instruction from the proponent.

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1.1.1.5 Monitoring of equipment
NORM is initially evaluated by measuring the gamma radiation emitted. Although this measurement does not directly measure the more significant hazard of alpha and beta radiation from the material, the measurement of gamma radiation serves as an index to the presence and degree of NORM contamination. Clearance of contaminated equipment should only be carried out by trained operators and monitored by the Safety Adviser. All monitoring equipment should be fully operational and within its calibration period. A check on the operational status of all radiological monitoring equipment should be maintained (Figure 7). An administrative system should be implemented to identify items which are naturally occurring radioactive material contaminated from those that have been cleaned.

MANAGEMENT OF NORMALLY OCCURING RADIOACTIVE MATERIALS DECONTAMINATION IN PROGRESS

Figure 7: Naturally occurring radioactive materials site

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5.0 Personal Protective Equipment

5.1 Personal Protective Equipment - general
Personnel must be protected from the inhalation and or ingestion of NORM dust and particulate from the dry scale or sludge found in contaminated tubular and equipment. The gamma radiation is a marker, indicating the possibility of alpha and/or beta radiation in the scale. The following safety precautions will be taken when the potential for exposure to NORM particulate exists: Check the radiation dose rate level of all NORM sludge and scale coated equipment Avoid direct contact with radioactive scale and solids whenever possible Do not eat, drink, smoke, or chew tobacco in work areas where NORM equipment is being surveyed or handled Wash thoroughly following any skin contact with NORM, particularly prior to eating, drinking, smoking, or chewing Cover openings of contaminated pipe and equipment with thread protectors or other suitable coverings Use plastic ground covers when performing maintenance to facilitate clean-up operations and prevent contaminating the ground Keep NORM contaminated material damp or wet when possible to minimize the generation of airborne radioactive materials Use appropriate PPE when NORM contamination of the workers clothing and person could result from working with or handling the NORM contaminated tubular or equipment. The PPE is not to protect against the gamma radiation, which is simply a marker for the presence of NORM in the equipment. The PPE will protect workers from the particulates that contain alpha and beta radiation that can enter the body to cause damage

PPE includes: Tyvek or other brand disposable suit Disposable gloves to keep dust off hands Half mask or full face respirator with P-100 filter. Workers who have handled NORM contaminated items must wash hands thoroughly at the end of the task, and shower at the end of the work shift

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5.2

Radiation barrier tape and signs

Yellow signs with standard radiation symbol in magenta or black (Figure 8) Yellow or magenta rope, tape, chains or other barriers (Figure 9) Yellow tags and labels with the standard radiation symbol in magenta or black

All radiological areas are identified by one or more of the following types of signs:-

CAUTION

RADIATION AREA
Figure 8: Radiation warning tape Figure 9: Radiation warning sign

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Appendix 1 - Training, competence and authorisation

All personnel directly involved with handling of radioactive material shall have received training in the practical application of this procedure. The training will include: Awareness of the hazards associated with naturally occurring radioactive material The controls that are required for their protection The methods for preventing human exposure and environmental contamination How to handle storage and disposal of NORM

Training shall focus on operational personnel who are potentially exposed to naturally occurring radioactive material and directly involved in maintenance operations. The training will permit them to ensure that the work they do pays due regard to the hazards of naturally occurring radioactive material and prevents the spread of naturally occurring radioactive material contamination. Personnel will require refresher training under any of the following conditions: Changes in the workplace render previous training obsolete Legislation for naturally occurring radioactive material is amended or changed

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Appendix 2 - Compliance and auditing

It is essential that complete records are maintained of all naturally occurring radioactive materials found and disposed of at Rumaila facilities. The Environmental Department will maintain these records. The following information will be held: Naturally occurring radioactive material records

Records will be kept at the facility for at least two years before they can be archived. Archived records will be kept for the lifetime of the facility.

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