What do Workers in the Field Need to
Know About NORM/TENORM
Alan Fellman, Ph.D., C.H.P.
Dade Moeller & Associates, Inc.

• Definitions
• Sources and types of NORM/TENORM
• NORM Regulations
• Oil and Gas Industry NORM Wastes
• NORM/TENORM Radiation Safety
December 2-3, 2014

NORM as a Public Health Issue and a Public Perception Issue
• Basic interactions of people and their environment
• Must understand, assess, and control
– Impacts of people on their environment
– Impacts of the environment on people
• Oil and Hydraulic Fracturing waste may contain radioactive materials
 What are these materials?
 When is this a concern?
 When/how is it regulated?
December 2-3, 2014

NORM: Naturally Occurring
Radioactive Material – U, Th, Ra, Rn, etc.
or if you prefer:
Cheers regular; loves beer
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Some oil and gas drilling waste (shale)
Fertilizer (from phosphate ores – uranium)
Rare earth mine tailings (uranium, thorium)
Ceramic products (uranium in clay)
Welding rods (thorium sands in coatings)
December 2-3, 2014

• TENORM: Technologically Enhanced NORM
– natural material whose radioactive concentrations have been enhanced by human activities including:
 Oil & gas pipe scale
 Oil & gas sludges
 Selected mining wastes
 Coal ash (concentrated uranium & thorium)
December 2-3, 2014

Ionizing Radiation –
Why Worry?
• Ionizing radiation health risks:
 Acute effects – high levels of radiation produce effects such as blood chemistry changes, nausea, fatigue, various skin effects, cataracts, and death
 Delayed effects – at some lower level of radiation, can increase risk of some cancers
• What about at typical environmental and occupational dose levels? No risk? Hormesis?
What are the implications?
• Radiation is a weak carcinogen compared to other materials (beryllium, asbestos, tobacco smoke…)
December 2-3, 2014

People around the world are continually exposed to radiation from natural sources
• These sources include:
 Cosmic radiation from outer space
 Terrestrial radiation (materials in the earth)
• Internal radiation from materials taken into the body through breathing air, drinking water, and eating foods
December 2-3, 2014

Sources and Types of
NORM/TENORM
• Oil field pipe scale (radium)
• Oil field/refinery sludge (radium)
• Geothermal waste (radium)
• Drinking water purification waste
(uranium/radium)
• Metals and tailings from certain ores
(rare earth elements)
• Coal fly/bottom ash
December 2-3, 2014

• NORM/TENORM present in all phases
• Concentrations depend on geology
 Higher concentrations in production phase
(scale/sludge)
 Drill cuttings
 Produced water/flowback water
 Radon decay products in gas production equipment
• Gas well drillers often use well logging to determine radiation levels to find gas
December 2-3, 2014

• Radon gas, external exposure, internal exposure
• Potential:
 Worker exposure
 General public exposure (and associated litigation risks)
 Environmental impact
December 2-3, 2014

• EPA – sets federal radiation standards for the public
• OSHA – has authority over hazardous materials in the workplace
• States
 NORM-specific regulations
 Clean Air Act
 Clean Water Act
 Workplace dose rates
 Waste management
December 2-3, 2014

• Generators have the responsibility to know about their waste and appropriate management
– DOT HAZMAT issues
• Generators should know waste characterization:
 Can be done through analytical testing, or
 Through generator knowledge of a waste based on defensible and demonstrated factors
 If uncertain, generators have the responsibility to perform analytical testing
December 2-3, 2014

• NORM radionuclides may be concentrated in the oil recovery process
 Radium is more soluble in brine solutions than uranium or thorium
 Carbonates and sulfates of calcium, barium, and strontium may precipitate as pipe scale
 Radium will also precipitate in pipe scale
 Sludge in refineries may also contain radium
December 2-3, 2014

Oil Field Waste: Example
Radionuclide Content
Radionuclide
Average Sludge Average Scale pCi/g pCi/g
210 Po
210 Pb
226 Ra
228 Th
228 Ra
Total:
56
56
56
19
19
206
360
360
360
120
120
1,320
Note: Typical radium-226 in soil is ~1 pCi/g
* EPA Data
December 2-3, 2014

Oilfield NORM/TENORM – Who is
Exposed?
• General site workers
• Maintenance personnel – cutting, grinding, welding, scraping, dismantling pipes
(scale/sludge)
• Pipe/equipment recyclers
• Personnel involved in remediation and decontamination operations
• Waste handlers/transporters
December 2-3, 2014

Oilfield NORM/TENORM – Who
Else Could be Exposed?
• Members of the public
– Landowners who have leased mineral rights
– Transportation of wastes containing radioactive materials
– Water treatment plant workers – they are members of the public with respect to radiation regulations
• Legal Implications?

Radiation Safety at a NORM
Facility
• Written Radiation Safety Program
• Training
• Survey Activities:
 Instrument surveys for dose rate, contamination
 Collect airborne dusts
 Restrict pipe cutting area
 PPE – air filter, gloves, other
December 2-3, 2014

Radiation Safety at a NORM
Facility (continued)
• Instrumentation
• Dose Monitoring
• Record-keeping – if there’s no record, then it wasn’t done
– Can you defend your program if challenged?
– We live in a very litigious society so this can’t be stressed enough

What it all means to the operator
• Be familiar with your State’s regulations
• Develop a worker protection plan
• Manage and dispose of NORM waste properly
• Provide NORM training to workers
• Know your NORM environment:
 Sampling
 Field Measurements
December 2-3, 2014

• Not all States Regulate NORM/TENORM
• Wide range of State regulations
• Several States considering regulation of
TENORM
• Increase in oil and gas drilling in northern states
December 2-3, 2014

Contact Information:
Alan Fellman
(301) 990-6006 ext. 3302 alan.fellman@moellerinc.com
December 2-3, 2014