NORM Regulatory Scene
(an international perspective)
Gert Jonkers
Engineering & Analytical - GSEA/4 “Problem Solving”
(Shell E&P Ionising Radiation/NORM HSE Expert CHP)
location
Shell Research & Technology Centre, Amsterdam
P.O. 38000
NL-1030 BN Amsterdam
the Netherlands
E&P NORM: What to Monitor?
2
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
COLLOQUIAL TERMINOLOGY for NORM
LSA
maximum NOR-concentrations (15,000 Bq[226Raeq]/g; 2,000
Bq[210Pbeq]/g and 2,800 Bq[228Raeq]/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 (NOR’s): 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 NOR’s as a minor component
or contaminant. As most natural resources do contain NOR’s (average
concentrations in the Earth's crust: 4.2 ppm[U] or 0.05 Bq[238U]/g, 12
ppm[Th] or 0.05 Bq[232Th]/g) all these may termed NORM, no matter
how low the NOR-concentrations are.
3
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
(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 Act’s”) 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.
4
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
tel. +31 20 630 3424
NORM
Workshop
TENORM encountered in theE&P
gas/oil
industry
will be denoted byGert.Jonkers@Shell.com
E&P NORM
Muscat, February 21-24, 2005
E&P NORM History
1918
“Radioactivity of the Natural Gases” (Satterly et al.)
1928
“Radioactivity Oil Fields” (Tscherepennikov et al.)
50’s
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 NOR’s of radium).
70’s
E&P 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.
80’s
Extending the NORM issue inventory.
90’s
Struggle to implement the non-nuclear [TE]NORM HSE issue under
“Basic Safety Standards”
5
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
1
1928
1959
1964
1966
1977
1978-87
1991
2005
Radium Commission (International Society of Radiology): with time
widened from protection in medical radiology to all aspects of
protection against ionising radiation
New publication series started:
Publication 1 – Recommendations of the ICRP
Publication 6 – Recommendations of the ICRP
Publication 9 – Recommendations of the ICRP
Publication 26 – Recommendations of the ICRP
Implemented in
Amendment Statements at various Meetings
Ionising Radiation Safety
Guide
Publication 60 – Recommendations of the ICRP
.
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.
6
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
2
Annals of the ICRP
Annals of the ICRP
Annals of the ICRP
A Compilation of
Dose Conversion
Radiation Protec
for Members of the
Principals for the Recommendations of the
Disposal of Soli International Commission on
Radioactive W Radiological Protection
Publication 60
Publication 60
PERGAMON PRESS OXFORD
Publication 60
PERGAMON PRESS OXFORD
PERGAMON PRESS OXFORD NEWYORK FRANKFURT
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
7
G. Jonkers, GSEA/4 at SRTCA
World-Wide (population)
averaged
Natural Background Dose
E&P NORM
Workshop
P.O. Box 38000, 1030 BN Amsterdam
Sv/y
Muscat,2,400
February
21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
3
Drawbacks 1990 Recommendations:
 E&P 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 E&P NORM encounter) may the economic and social
benefits stemming for gas/oil production.
 No specific guidance is provided on E&P 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
 [TE]NORM may be a burden for non-nuclear industries (e.g. gas/oil
production [E&P NORM], ore extraction and gas/oil/ore processing)
Implemented in
Ionising Radiation Safety
Guide
• 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
• [TE]NORM 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
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
8
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
Late 80’s/Early 90’s: “E&P 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 “E&P 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 E&P 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 E&P
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.
9
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
1996: IAEA Basic Safety Standards & E&P 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’ scenario’s referenced
against a dose criterion of 10 Sv[individual]/y and 1 manSv[collective]/y.
 Regulatory and HSE definition’s for NOR’s, 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 NOR’s applied in ‘on-purpose‘ radiation sources (so these exempt
limits are not applicable for E&P 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 IAEA’s statutory objectives is to establish radiation protection standards.
10
G. Jonkers,
GSEA/4
at SRTCA
tel. +31
20 630
IAEA BSS
jointly sponsored
by the FAO (Food and Agriculture Organisation of the United Nations), IAEA (International Atomic Energy
Agency),
ILO3424
E&P NORM Workshop
(International
Labour
Organisation),
NEA(OECD) (Nuclear Energy Agency of the Organisation for Economic Co-operation and Development),
PAHO (Pan
P.O.
Box 38000,
1030
BN Amsterdam
Gert.Jonkers@Shell.com
American Health
Organisation
and WHO21-24,
(World Health
Muscat,
February
2005Organisation)..
1996: 96/29/Euratom Directive & E&P 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 scenario’s referenced
against a dose criterion of 10 Sv[individual]/y and 1 manSv[collective]/y.
 Regulatory and HSE definition’s for NOR’s, 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 NOR’s applied in ‘on-purpose’ radiation sources (so these exempt
limits are not applicable for E&P NORM exempt limits)
 Harmonisation with the IAEA Basic Safety Standards.
11
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
96/29/Euratom Guidance & E&P NORM
‘Work Activities (E&P 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)
12
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
ESTABLISHMENT OF GENERAL EXEMPT LIMITS
RISK
Likelihood of Fatal Cancer
DOSE
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
“Forward” Calculation - Applied
for Deriving Unconditional Release
(Exempt) Limits or
for Determining Compliance with
Dose or Risk Standards
Source Dose Constraint
to be endorsed by the
Competent Authority
13
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
European Union Recommended ‘Exempt’ Limits
Regulatory Terminology
General Clearance Level
General Exempt Level
>> Unconditional Release Limit <<
14
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
Late 90’s till now: “E&P NORM Regulations”
United States: still quarrelling between EPA and state departments who
sits in the driving seat to regulate NORM (“How far should a riskbased 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 Sv/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 E&P NORM regulations.
Middle East: several gas/oil producing states (Egypt, Oman, Syria, UAE) start
to issue national E&P NORM Regulations.
15
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
NORM Source Constraints & Unconditional Release Limit
16
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
2005 draft Recommendations
(Justification) > Optimisation (ALARA) > Dose Limitation
Radiation Worker (special medical controls, dose monitoring, etc.)
20,000 Sv/a
Members of the public (incl. non-radiation workforce)
1,000 Sv/y
NORM Source Constraint: handling/disposal materials/equipment
containing/contaminated with Naturally Occurring Radionuclides (NOR’s)
NORM Source Constraint
300 Sv/y
Unconditional Release Limits
1 Bq[NOR]/g[solid]
allowance to Derive Conditional Release Limits > approval by Regulatory Authority
Practice Source Constraint: handling/disposal materials/equipment
containing/contaminated with ‘on-purpose’ applied (artificial) radionuclides
Source Constraint for Practice Exempt Limits
10 Sv/y
Exemption/Clearance Limits provided in IAEA Basic Safety Standards
17
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com
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
EP 2005-0000
Standards,
procedures,
guidelines
Applied in all assets & departments
in EP plus a local layer
if required for any country regulation
and local risk requirements
Accompanied by two additional,
fairly detailed documents on
NORM
Practices
18
G. Jonkers, GSEA/4 at SRTCA
P.O. Box 38000, 1030 BN Amsterdam
E&P NORM Workshop
Muscat, February 21-24, 2005
tel. +31 20 630 3424
Gert.Jonkers@Shell.com