What Do Workers in the Field Need to Know about

Report
What do Workers in the Field Need to
Know About NORM/TENORM
Alan Fellman, Ph.D., C.H.P.
Dade Moeller & Associates, Inc.
Outline
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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
Definitions
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
Definitions (Cont’d)
• 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
Background Radiation
People around the world are continually
exposed to radiation from natural sources
• These sources include:
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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
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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
Oil & Gas Industry
• 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
NORM Contamination
• Radon gas, external exposure, internal
exposure
• Potential:
Worker exposure
General public exposure (and associated
litigation risks)
Environmental impact
December 2-3, 2014
Who Regulates NORM?
• 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
Waste Characterization
• 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
Oil Field Waste
• NORM radionuclides may be concentrated
in the oil recovery process
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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
210Po
210Pb
226Ra
228Th
228Ra
Total:
Average Sludge
pCi/g
Average Scale
pCi/g
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
Summary
• 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
Questions/Comments?
Contact Information:
Alan Fellman
(301) 990-6006 ext. 3302
[email protected]
December 2-3, 2014

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