NORM Regulatory Scene (an international perspective) Gert Jonkers

1. 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

2. E&P NORM: What to Monitor?

3. 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’). NORMMaterials 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.

4. (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. TENORM encountered in the gas/oil industry will be denoted by E&P NORM

5. 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”

6. Implemented in Ionising Radiation Safety Guide 1 1928 Radium Commission (International Society of Radiology): with time widened from protection in medical radiology to all aspects of protection against ionising radiation 1959 New publication series started: Publication 1 – Recommendations of the ICRP 1964 Publication 6 – Recommendations of the ICRP 1966 Publication 9 – Recommendations of the ICRP 1977 Publication 26 – Recommendations of the ICRP 1978-87 Amendment Statements at various Meetings 1991Publication 60 – Recommendations of the ICRP . 2005 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.

7. Annals of the ICRP Annals of the ICRP Annals of the ICRP A Compilation of Dose Conversion for Members of the Radiation Protec Principals for the Disposal of Soli Radioactive W Recommendations of the International Commission on Radiological Protection Publication 60 Publication 60 PERGAMON PRESS OXFORD Publication 60 PERGAMON PRESS OXFORD PERGAMON PRESS OXFORD NEWYORK FRANKFURT 2 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 World-Wide (population) averaged Natural Background Dose 2,400 mSv/y

8. Implemented in Ionising Radiation Safety Guide 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) • 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

9. 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.

10. 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 mSv[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. IAEA BSS jointly sponsored by the FAO (Food and Agriculture Organisation of the United Nations), IAEA (International Atomic Energy Agency), ILO (International Labour Organisation), NEA(OECD) (Nuclear Energy Agency of the Organisation for Economic Co-operation and Development), PAHO (Pan American Health Organisation and WHO (World Health Organisation)..

11. 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 mSv[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.

12. 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 sourcesof 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)

13. ESTABLISHMENT OF GENERAL EXEMPT LIMITS RISK Likelihood of Fatal Cancer Source Dose Constraint to be endorsed by the Competent Authority DOSE “Forward” Calculation - Applied for Deriving Unconditional Release (Exempt) Limits or for Determining Compliance with Dose or Risk Standards 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

14. European Union Recommended ‘Exempt’ Limits Regulatory Terminology General Clearance Level General Exempt Level >> Unconditional Release Limit <<

15. 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 risk- based 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 mSv/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.

16. NORM Source Constraints & Unconditional Release Limit

17. 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

18. EP Global HSE Standards and Procedures(Integrated in the EP MS – Future 2004+) EP 2005-0000Standards,procedures,guidelines Yellow guides Group Ionising Radiation Protection Guide 2005 Yellow Part “ shall statements ” and incorporating the 2005 ICRP Recommendations Accompanied by two additional, fairly detailed documents on NORM Practices Applied in all assets & departments in EP plus a local layer if required for any country regulationand local risk requirements