NORM Management System (Shell Group HSE MS) Gert Jonkers

1. NORM Management System (Shell Group HSE MS) 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

2. FLARE FUEL GAS FLARE K.O. DRUM GAS SCRUBBER GAS SCRUBBER METERING PACKAGE EXPORT LINE 2ND STAGE SEPARATOR 1ST STAGE SEPARATOR DEHYDRATOR PRODUCTION MANIFOLD OIL SHIPPING PUMP SKIMMED OIL PUMP FLOTATION CELL DE- AERATOR WELLHEADS S.W.SERVICES COOLERS ETC. SEA WATER PUMP PRODUCTION TUBING OVERBOARD PUMP WATER FLOOD INJECTION SEA WATER BOOSTER PUMP EXPLOIT ALL a priori KNOWLEDGE ON E&P NORM

3. Effective Radiation Protection Programme IAEA, Operational Radiation Protection - Safety Guides, Safety Series 101 1990 IAEA, Recommendations for the Safe Use and Regulation of Radiation Sources in Industry, Medicine, Research and Teaching, Safety Series 102, 1990 Organisation & Management committed to Safety & ALARP Successful Personnel Selection & Training Effective Occupational Radiation Control Effective Public Radiation Control Effective Emergency Planning & Preparedness Implementation Quality Assurance • Effective Management Structure • Clearly Documented Authorities, Responsibilities, Job descriptions • Adequate resources • Commitment to Safety & ALARP from all Employees • Appropriate Selection Criteria • Complete Post-Appointment Training • Effective Control of Doses and Intakes • Adequate Control Standards • Effective Surveillance • Identification of Potential Sources of Public Exposure • Adequately Derived and Documented Criteria to Limit Public Exposure • Identification Potential Accident Situations • Evaluation Unidentified Accident Situations • Preparation Contingency Plans • Exercise Contingency Plans • Periodic Review Emergency Plans • Identification of Components Requiring Formal Quality Assurance • Identification of Applicable Standards • Adequate Appraisal Regimes ad 1) documented qualification requirements for all levels, minimum age requirements, identified and documented medical requirements ad 2) formal review training requirements, documented training objectives, adequate scope of training programme, induction training to rectify deficiencies ad 1) adequate control of source, provision of physical barriers, provision of administrative controls ad 2) adequately derived standards, adequately documented standards, pre-determined reference and action levels ad 3) adequate monitoring of workplace, appropriate personal dosimetry, assessment of results and data of occupational radiation control ad 1) adequate control of public doses due to > accident situations, > routine releases, > transport of radioactive materials, > radioactive waste ad 2) individual and collective doses ad 1) equipment / procedure oriented ad 2) satisfy self-determined / external / national standards ad 3) defined appraisal committee / frequency of appraisals / scope of appraisals ad 1) location, cause ad 2) evaluation of non-radiological conseq./ hazard / personnel-at-risk / consequences ad 3) statements potential situations & identifiable hazards, provision of adequate communicat., recommended course of action, availability emergency equipment, notifications outside organisation, plans for exposed personnel ad 4) degree of involvement, frequency ad 5) scope/frequency review ad 1) adequate corporate/site structure, seniority safety management, safety independent of production ad 2)production/safety: publish policies, clear organisation chart ad 3)production/safety: competent staff, adequate facilities ad 4) training, appraisal ratings include safety performance

4. Evolution of HSE Management Systems Assurance Safety Safety (HSE) Management System Line Management Focus Human Error Focus equipment focus 1970 1980 1990 2000 1960 Past Present TRENDS Safety engineers / officers Line management responsibility supported by safety (HSE) advisers Reaction to accidents Prevention of accidents Accidents accepted Accidents can severely erode the reputation/results of the Company Prescriptive rules Goal setting rules risk based Safety was a side issue HSE is a core issue

5. PLAN DO CHECK HSE Management System Structure Leadership and Commitment Policy and Strategic Objectives Organisation, Responsi-bilities, Resources, Standards and Documents Hazards and Effects Management Corrective Action Planning and Procedures FEEDBACK Implementation Monitoring Corrective Action and Improvement Audit Corrective Action and Improvement Management Review

6. Leadership & Commitment • Specific requirements for (E&P) NORM (draft) • Company Management shall ensure that extracted natural resources (e.g. Oil, Gas, Tar sands, Coal) are evaluated on NORM contents and that methods to reduce production are considered. • All persons that can potentially be exposed to NORM shall be informed. • Site owner shall assess the risk of NORM contained in feedstock or purchased materials based on extracted natural resources and minimize the quantities imported. • Site owner shall check and have an inventory of accumulations of NORM in company and contractor equipment. • Management to make sure that a qualified person is assigned to advice on dealing with the NORM. Accountability for managing NORM rests with site management. • Receivers of products and waste streams from contaminated installations shall be made aware of the NORM contents. • Company and contractor organisations maintaining or demolishing the installations shall be made aware of contaminations and the correct disposal route. • Emergency response plans shall deal with the reputation aspects of inadvertent handover or disposal of NORM containing product, equipment or waste

7. Potential Embedment of NORM (IR Protection) Know How Company Managing Director/Board Radiation (NORM) Advisory Committee Chair: HSE Manager Members: Managers of “NORM-affected” operations (incl. contractors) Company Radiation Focal Point External Radiation Protection Advisor Operations Radiation Focal Point Field/Asset Radiation Focal Points Field/Asset HSE advisors (Radiation Protection Technicians) (HSE critical activities)

8. Hazard and Effects Management Process (HEMP) Are people, environment or assets exposed to potential harm? Identify What are the causes and consequences? How likely is loss of control? What is the risk and is it ALARP? Assess Can the causes be eliminated? What controls are needed? How effective are the controls? Control Can potential consequences or effects be mitigated? What recovery measures are needed? Are recovery capabilities suitable and sufficient? Recover

9. MODES OF (NATURAL) DECAY 222Rn 218Po +a emission of mono-energetic, fast (MeV) He nuclei 214Pb 214Bi + b emission of poly-energetic, fast (keV< >MeV) electrons hn 234mPa 234Pa + g emission of mono-energetic, penetrative (keV< >MeV) photons

10. RADIATION PENETRATION CHARACTERISTICS

11. g POTENTIAL EXPOSURE & ASSESSMENT Inhalation (Bq/m3) airborne & radon contaminates body (lungs) Intake (Bq) & DCCinh (Sv/Bq): internal dose (Sv) Ingestion (Bq/L, Bq/g) contaminates body (stomach) Intake (Bq) & DCCing (Bq/Sv): internal dose (Sv) Irradiation by g-photons from outside the body Dose rate (mSv/h) / exp. Time (h): external dose (Sv) surface dose rate (mSv/h per Bq/cm2) / exp. time (h):……… skindose (Sv) Contamination (Bq/cm2) of the outside body (skin) Dose Conversion Coefficient (Bq/Sv, ex ICRP #72) Radionuclide Specific Sum  whole body dose (Sv)

12. The Bow Tie model CONSE QUENCE HAZARD SCENARIO TopEvent CONSE QUENCE THREAT RECOVERY PREPAREDNESS MEASURES CONSE QUENCE BARRIERS Control (keep within control limits) Prepare for emergencies Objective: reduce likelihood (pro-active/preventative) Objective: mitigate consequences and re-instate (reactive)

13. Possible End Consequences from a Top Event People NORM no acute effects chronic exposure Environment discharges to air & water; waste Reputation

14. HSE Commitment and Risk Management HSE Commitment Target tasks responsibilities competencies procedures

15. FROM DOSE TO RISK LEVELS • Hazard Identification: • NORM exposure within in stochastic (chronic) dose regime, i.c. no deterministic (acute) effects • Epidemiological data shown conclusively that ionising radiation can cause cancer in human beings. • Dose-Response Relationship: • Absorbed dose in tissue is the physical fundamental quantity, that determines the response, NOT the source of radiation; • Estimates stem from special groups exposed well above natural levels, like Japanese bomb survivors, uranium miners, radium dial painters; • Linear function of dose without a threshold (LNT-model; UNSCEAR 5% per Sv). • Exposure Assessment: • Similar for (naturally occurring) radionuclides and other hazardous chemicals except that external exposure to penetrating radiation is an important pathway. • Risk Characterisation: • Relatively straightforward, and generally focuses on fatal cancers as the endpoint of concern (LNT-model; UNSCEAR = 5% per Sv adopted by ICRP).

16. Individual Risk Per Annum 10-3 die per year 10-4 die per year 10-5/year 10-6/y Quantified Risk Assessment Levels (QRA) Fundamental improve-ments needed. Only to be considered if there are no alternatives and people are well informed. Intolerable Too high, significant effort required to improve. natural background dose The ALARP or Tolerable Risk Region (Risk is tolerated only and risks have to be managed to ALARP) High, investigate alternatives public dose limit NORM source constraint Low, consider cost effective alternatives Broadly acceptable region. Negligible, maintain normal precautions practice source constraint No need for detailed working to demonstrate ALARP

17. g Operations - External Radiation Hazard TARGETMinimisation of Exposure to PenetrativeRadiation Emitted by NORM Deposits TIME Minimise the time spent in proximity of NORM affected facility parts. DISTANCE Maximise the distance to NORM affected facility parts. SHIELDING Maximise the shielding between personnel and NORM affected facility parts. Barriers Separation (Time & Distance) Administrative (Training, Warning) Procedural g

18. Maintenance - Internal & External Radiation Hazard TARGETPrevention of Internal Contamination by Naturally Occurring Radionuclides in Deposits (NORM) Ingestion Avoid direct skin contact with LSA deposits. No eating, drinking etc. at the workplace. Use PPE (e.g. gloves). Inhalation Avoid dust generating operations. Use PPE (e.g. respiratory protection). External Time (Distance/Shielding) applies as well. j b a a b Barriers Separation (Time & Distance) Administrative (Training, Warning) Procedural Repressive (ventilation, dust filtration) a b g

19. g ABANDONMENT - Internal & External Radiation Hazard TARGETReducing both External and Internal Dose by Naturally Occurring Radionuclides in Deposits (NORM ) from former Gas/Oil Production Activities to an Acceptable Level for Future Inhabitants Ingestion Determine amount of radioactivity entering food chain. Inhalation Potential (topsoil) dust activity levels extremely low. External (Sub)soil activity levels sufficient low. Barriers Administrative (Training, Warning) Procedural Preventative (area cover, collection) Repressive (ventilation, dust filtration) Recovery Preparedness Curative (cleanup, remediation) Compensatory a b g

20. Review & Corrective Actions Dose records and/or dose assessments, NORM surveys, NORM analysis results, NORM production (notification & licensing?) should be reviewed regularly by the Radiation Advisory Committee defining Corrective Actions for Improvement

21. SYSTEMATIC APPROACH TO PROTECTION AGAINST “NORM” “OPERATIONS”NORM (external/contamination) radiation survey dose readings > 0.5mSv/h NORM contaminated or contamination readings > 50 bg signpost areas 0.1mSv/h < dose readings < 0.5mSv/hNORM suspect or5 bg < contamination readings < 50 bg dose readings < 0.1mSv/h no NORM restrictions andcontamination readings < 5 bg “MAINTENANCE” NORM (external/contamination) readings ad hoc NORM contaminated: take external and contamination readings for open tanks/vessels, working hours, asses dose, Waste Storage NORM suspect: take external and contamination readings for open tanks/vessels, record working times, take ‘representative’ sample Analyse for final classification of waste: normal / NORM

22. Risk of Radiation Doses Compare with Natural Background Dose