TENORM Radiation SafetyFrom Oil and Gas ProductionTENORM Radiation SafetyFrom Oil and Gas Production
Alan Fellman, Ph.D., C.H.P.Alan Fellman, Ph.D., C.H.P.
Dade Moeller & Associates, Inc.Dade Moeller & Associates, Inc.
Just To Be ClearJust To Be Clear
We’re talking about this NORM:We’re talking about this NORM:
Not talking about this Norm:Not talking about this Norm:
Corner stool atCheers; loves beerCorner stool atCheers; loves beer
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OutlineOutline
DefinitionsDefinitions
Sources and types of NORM/TENORMSources and types of NORM/TENORM
NORM/TENORM RegulationsNORM/TENORM Regulations
TENORM Radiation SafetyTENORM Radiation Safety
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NORM: Naturally Occurring RadioactiveMaterial – U, Th, Ra, Rn, PoNORM: Naturally Occurring RadioactiveMaterial – U, Th, Ra, Rn, Po
We live on a radioactive planetWe live on a radioactive planet
Radioactivity is found everywhereRadioactivity is found everywhere
SoilSoil
RockRock
PlantPlant
AnimalAnimal
We are exposed 24/7We are exposed 24/7
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TENORM – TechnologicallyEnhanced NORMTENORM – TechnologicallyEnhanced NORM
Natural material whose radioactiveconcentrations have been enhanced byhuman activities including:Natural material whose radioactiveconcentrations have been enhanced byhuman activities including:
Oil & gas pipe scaleOil & gas pipe scale
Oil & gas sludgesOil & gas sludges
Water treatment filter mediaWater treatment filter media
Natural gas processing equipmentNatural gas processing equipment
December 2-3,
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Ionizing Radiation – Why Worry?Ionizing Radiation – Why Worry?
Ionizing radiation health risks:Ionizing radiation health risks:
Acute effects – high levels of radiation produceeffects such as blood chemistry changes, nausea,fatigue, various skin effects, cataracts, and deathAcute effects – high levels of radiation produceeffects such as blood chemistry changes, nausea,fatigue, various skin effects, cataracts, and death
Delayed effects – at some lower level of radiation, canincrease risk of some cancersDelayed effects – at some lower level of radiation, canincrease risk of some cancers
Radiation is a weak carcinogen compared toother materials (beryllium, asbestos, tobaccosmoke…)Radiation is a weak carcinogen compared toother materials (beryllium, asbestos, tobaccosmoke…)
What about at typical environmental andoccupational dose levels? No risk? Hormesis?What are the implications?What about at typical environmental andoccupational dose levels? No risk? Hormesis?What are the implications?
December 2-3,
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TENORM Exposure PathwaysTENORM Exposure Pathways
Radon gas, external exposure, internalexposureRadon gas, external exposure, internalexposure
Potential:Potential:
Worker exposureWorker exposure
General public exposure (andassociated litigation risks)General public exposure (andassociated litigation risks)
Environmental impactEnvironmental impact
December 2-3,
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Oil & Gas IndustryOil & Gas Industry
NORM/TENORM present in all phasesNORM/TENORM present in all phases
Concentrations depend on geologyConcentrations depend on geology
Higher concentrations in production phase(scale/sludge)Higher concentrations in production phase(scale/sludge)
Drill cuttingsDrill cuttings
Produced water/flowback waterProduced water/flowback water
Radon decay products in gas productionequipmentRadon decay products in gas productionequipment
December 2-3,
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Which Regulations Govern MyOperation?Which Regulations Govern MyOperation?
Some Federal regulations ‘touch’ onNORMSome Federal regulations ‘touch’ onNORM
EPAEPA
OSHAOSHA
DOTDOT
It really boils down to what State(s) do Ioperate inIt really boils down to what State(s) do Ioperate in
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Regulations OverviewRegulations Overview
EPA – sets federal radiation standards for thepublicEPA – sets federal radiation standards for thepublic
OSHA – has authority over hazardousmaterials in the workplaceOSHA – has authority over hazardousmaterials in the workplace
DOT – transportation of hazardous materials,including radioactivity, such as NORMDOT – transportation of hazardous materials,including radioactivity, such as NORM
StatesStates
NORM-specific regulationsNORM-specific regulations
Workplace dose rates; concentration limits in soilWorkplace dose rates; concentration limits in soil
Waste managementWaste management
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Federal Agencies - EPAFederal Agencies - EPA
Airborne releases from phosphate industry anduranium mines under CAAAirborne releases from phosphate industry anduranium mines under CAA
Liquid discharges of TENORM from U mines andmills under CWALiquid discharges of TENORM from U mines andmills under CWA
Superfund site cleanupsSuperfund site cleanups
Office of Water published proposedpretreatment standards prohibiting dischargesof unconventional O&G extraction wastewater topublically owned wastewater treatment plants –April 7, 2015Office of Water published proposedpretreatment standards prohibiting dischargesof unconventional O&G extraction wastewater topublically owned wastewater treatment plants –April 7, 2015
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Federal Agencies - OSHAFederal Agencies - OSHA
The regulator when workers are notcovered under a materials license andare not Federal employeesThe regulator when workers are notcovered under a materials license andare not Federal employees
Why? Because radiation is defined as aworkplace hazard under OSHA regulationsWhy? Because radiation is defined as aworkplace hazard under OSHA regulations
The Reality – not actively regulating this orany radiation hazardsThe Reality – not actively regulating this orany radiation hazards
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Federal Agencies - DOTFederal Agencies - DOT
Generators have the responsibility toknow about their waste and appropriatemanagementGenerators have the responsibility toknow about their waste and appropriatemanagement
Waste characterizationWaste characterization
Can be done through analytical testing, orCan be done through analytical testing, or
Through generator knowledge of a wastebased on defensible and demonstratedfactorsThrough generator knowledge of a wastebased on defensible and demonstratedfactors
If uncertain, generators have theresponsibility to perform analytical testingIf uncertain, generators have theresponsibility to perform analytical testing
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Oil Field Waste: ExampleRadionuclide ContentOil Field Waste: ExampleRadionuclide Content
Average Sludge Average ScaleAverage Sludge Average Scale
Radionuclide pCi/g*pCi/g*Radionuclide pCi/g*pCi/g*
210Po56360210Po56360
210Pb56360 210Pb56360
226Ra56360226Ra56360
228Th19120228Th19120
228Ra19120228Ra19120
Total2061,320 Total2061,320
270 pCi/g Ra-226, Ra-228 subject to DOT regulation.Typical background radium-226 in soil is ~1 pCi/g270 pCi/g Ra-226, Ra-228 subject to DOT regulation.Typical background radium-226 in soil is ~1 pCi/g
* EPA Data * EPA Data
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StatesStates
16 states have regulations coveringTENORM16 states have regulations coveringTENORM
Another 9 have regulations and/orguidance addressing NORMAnother 9 have regulations and/orguidance addressing NORM
CRCPD Part N suggested TENORMregulationsCRCPD Part N suggested TENORMregulations
Check your State regs!Check your State regs!
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Some Common Threads InDetermining If ExemptSome Common Threads InDetermining If Exempt
More robust regulatory programs intraditional oil producing States across thesouth; much less so in the newer gasregionsMore robust regulatory programs intraditional oil producing States across thesouth; much less so in the newer gasregions
50 μR/h (sometimes includingbackground, sometimes not) from surfaceof equipment50 μR/h (sometimes includingbackground, sometimes not) from surfaceof equipment
5 pCi/g radium (usually abovebackground); not easy to determine withhand-held instrument5 pCi/g radium (usually abovebackground); not easy to determine withhand-held instrument
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Do We Need A License?Do We Need A License?
It depends onIt depends on
What State you’re inWhat State you’re in
What you doWhat you do
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Where To Send Waste ForDisposalWhere To Send Waste ForDisposal
Some waste acceptance criteria examples (5 states havelandfills that can accept > 50 pCi/g)Some waste acceptance criteria examples (5 states havelandfills that can accept > 50 pCi/g)
Texas:Idaho:Texas:Idaho:
Radium-226: 30 pCi/gRadium (Ra-226 + Ra-228)Radium-226: 30 pCi/gRadium (Ra-226 + Ra-228)
Pb-210: 150 pCi/gBulk: 500 pCi/gPb-210: 150 pCi/gBulk: 500 pCi/g
Equipment: <50 μR/hrIP-1 package: 1,500 pCi/gEquipment: <50 μR/hrIP-1 package: 1,500 pCi/g
Michigan:Washington:Michigan:Washington:
Radium-226: 50 pCi/gRadium-226: 10,000 pCi/gRadium-226: 50 pCi/gRadium-226: 10,000 pCi/g
Pb-210: 260 pCi/gPb-210: no upper limitPb-210: 260 pCi/gPb-210: no upper limit
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What About Injection Well DisposalFor O&G NORM Wastewater?What About Injection Well DisposalFor O&G NORM Wastewater?
MaybeMaybe
Injection wells in Ohio, Louisiana,Texas, Alaska, N.D.Injection wells in Ohio, Louisiana,Texas, Alaska, N.D.
Elsewhere – wastewater treatmentplant followed by landfill disposal offilter cakeElsewhere – wastewater treatmentplant followed by landfill disposal offilter cake
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Oilfield NORM/TENORM – WorkersExposed?Oilfield NORM/TENORM – WorkersExposed?
Maintenance personnel – cutting,grinding, welding, scraping,dismantling pipes (scale/sludge)Maintenance personnel – cutting,grinding, welding, scraping,dismantling pipes (scale/sludge)
Pipe/equipment recyclersPipe/equipment recyclers
Personnel involved in remediation anddecontamination operationsPersonnel involved in remediation anddecontamination operations
Waste handlers/transportersWaste handlers/transporters
December 2-3,
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Oilfield NORM/TENORM – WhoElse Could be Exposed?Oilfield NORM/TENORM – WhoElse Could be Exposed?
Members of the publicMembers of the public
Landowners who have leased mineralrightsLandowners who have leased mineralrights
Transportation of wastes containingradioactive materialsTransportation of wastes containingradioactive materials
Water treatment plant workers – they aremembers of the public with respect toradiation regulationsWater treatment plant workers – they aremembers of the public with respect toradiation regulations
Legal Implications?Legal Implications?
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TENORM Radiation SafetyTENORM Radiation Safety
Written Radiation Safety ProtocolsWritten Radiation Safety Protocols
TrainingTraining
Survey Activities:Survey Activities:
Instrument surveys for dose rate,contaminationInstrument surveys for dose rate,contamination
Air monitoring?Air monitoring?
PPE – air filter, gloves, otherPPE – air filter, gloves, other
December 2-3,
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TENORM Radiation Safety(continued)TENORM Radiation Safety(continued)
Dose MonitoringDose Monitoring
Record-keeping – if there’s no record,then it wasn’t doneRecord-keeping – if there’s no record,then it wasn’t done
Can you defend your program ifchallenged?Can you defend your program ifchallenged?
We live in a very litigious society so thiscan’t be stressed enoughWe live in a very litigious society so thiscan’t be stressed enough
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Common Sense Radiation Safety In AnUneven Regulatory EnvironmentCommon Sense Radiation Safety In AnUneven Regulatory Environment
Be familiar with your State’sregulationsBe familiar with your State’sregulations
Develop radiation safety proceduresDevelop radiation safety procedures
Provide radiation safety trainingProvide radiation safety training
Generate and maintain radiationsafety records, including dosimetryGenerate and maintain radiationsafety records, including dosimetry
KEEP IT REAL!!!KEEP IT REAL!!!
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Questions?Questions?
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Contact Information:
Alan Fellman
(301) 990-6006ext. 3302alan.fellman@dademoeller.com