21-23 February 2005 Muscat, Oman

1. Managing NORM from oil and exploration and production activities 21-23 February 2005 Muscat, Oman NSRW/WSS

2. Future Directions for Guidance on NORM Waste Management: An IAEA Perspective Peter Waggitt Waste Safety Specialist Decommissioning and Residues Unit Waste Safety Section, Department of Nuclear Safety International Atomic Energy Agency, Vienna NSRW/WSS

3. Naturally Occurring Radioactive Material(NORM) • NORM is widely distributed in the environment, often in large volumes and with relatively low specific activity • The source of the radioactivity is mostly the 238U and 232Th decay chains as well as 40K • Many of the decay products are long lived e.g. 226 Ra with half lives over 30 years • Many of these associated decay products usually end up in the waste stream • NORM waste can be large volumes with low activity, small volumes with high activity, or a mixture of both! • Waste containing NORM is a growing concern • Affected industries go beyond the “traditional nuclear list” and include phosphates, oil and gas, metal mining, water treatment, coal, etc. NSRW/WSS

4. IAEA and NORM • Thus NORM has been around a long time and NORM issues are growing in significance • IAEA has been working on a number of fronts to develop guidance on the issue of regulation and management • The Basic Safety Standard does not deal with NORM issues in detail and generally considers exposure of persons to be chronic and thus an intervention sistuation NSRW/WSS

5. IAEA and NORM - 2 • Worker protection and industrial situations have been a priority, now exposures potentially affecting the environment and the public are also in focus. • What justification is there to discriminate in regulation between radiation from different sources, i.e. natural or man made – a exposed cell can’t tell! • When dealing with NORM management we should never forget that radiation protection is only one aspect of the safety of dealing with these materials. Chemistry may be a greater potential risk to people and the environment. NSRW/WSS

6. A short history of IAEA activity relating to NORM • An IAEA Conference- “Topical Issues in Nuclear, Radiation and Radioactive Waste Safety” was held in 1998 One conclusion was that further guidance was needed on the issues of control of exposures to natural radiation • A Programme Performance Assessment carried out in 1999 recommended that a survey of Member States be undertaken to acquire the data: • which industries are mostly affected, • which processes might require control, and • which materials might require control? • This survey was also intended to provide the basis for an assessment of priority industries to be studied. NSRW/WSS

7. More Recent History • The Agency held a series of meetings to assess the situation: • May 2001 - Technical Consultants Meeting, Vienna: “Assessment of Occupational Protection Conditions in Workplaces with High Levels of Exposure to Natural Radiation” • November 2001 – Consultants Meeting, Vienna; assessed materials presented at the May 2001 TCM, the NORM III Symposium (Brussels) and a further TCM on the scope of regulatory control. The consultants then prepared Working Material for use in the development of an Action Plan • August 2002: International Conference, Geneva: “Occupational Radiation Protection” involving IAEA, WHO, ILO, EU, and OECD A significant conference outcome was the IAEA and ILO document : “Action Plan for Occupational Radiation Protection” which was formally approved by the IAEA Board of Governors on 8 September 2003 NSRW/WSS

8. Action Plan Recommendations • Collaboration between relevant agencies, especially IAEA and ILO • Definition of the scope of regulatory control • Provision of advice on a graded regulatory approach • Production of Sector Specific Safety Reports • Development of specialized training materials • Development of supporting actions in measurement and regulation • Facilitation of information exchanges using all media and methods NSRW/WSS

9. IAEA work so far • IAEA documents having a bearing on the NORM management issue 1995 Principles of Radioactive Waste Management Safety Fundamentals Safety Series No.  111-F 1999 Occupational Radiation Protection Safety Guide Safety Standards Series No.  RS-G-1.1 2002 Management of Radioactive Waste from the Mining and Milling of Ores Safety Guide Safety Standards Series No.  WS-G-1.2 Monitoring and Surveillance of Residues from the Mining and Milling of Uranium and Thorium Safety Reports Series No.  27 2003 Radiation Protection against Radon in Workplaces other than Mines Safety Reports Series No.  33 2004 Application of the Concepts of Exclusion, Exemption and Clearance Safety Guide Safety Standards Series No.  RS-G-1.7 NSRW/WSS

10. IAEA work so far - 2 Although not specifically relating to NORM and waste issues this recent Safety Guide is important There is a mention of the level of 1Bq/g as a point where NORM situations should be assessed for the need to regulate NSRW/WSS

11. IAEA work so far - 3 Generally industrial situations, including worker protection, as well as public and environmental exposures, have been studied, also waste management: 2002 Management of Radioactive Waste from the Mining and Milling of Ores Safety Guide Safety Standards Series No.  WS-G-1.2 2004 Occupational Radiation Protection in the Mining and Processing of Raw Materials Safety Guide Safety Standards Series No.  RS-G-1.6 NSRW/WSS

12. IAEA work so far - 4 Another significant recent publication related to NORM is: 2003 Extent of Environmental Contamination by Naturally Occurring Radioactive Material (NORM) and Technological Options for Mitigation Technical Reports Series No.  419 This report lists mining (mineral) industries affected, as well as oil and gas, coal, water treatment, geothermal energy and a variety of industrial processes all of which are affected by issues of NORM and NORM waste production and management NSRW/WSS

13. IAEA work so far - 5 • RS-G-1.6 is the top of a pyramid of relevant documents: • Industry related safety reports are being developed and the first one was published in 2003: Radiation Protection and the Management of Radioactive Waste in the Oil and Gas Industry Safety Reports Series No.  34 • A Safety Report relating to the Phosphate industry is in preparation • To be followed by Zircon and Titanium Dioxide as separate issues Later possible inclusions are: mineral sands, coal and coal ash • RS-G-1.6 has been developed into a module in the Post Graduate Education Course in Radiation Protection NSRW/WSS

14. The Oil and Gas Industry • The oil and gas industry is worldwide • A range of waste is produced some of which may be radioactive and some of that NORM derived • Radioactive waste of NORM origin may include scales and sludges from decontamination of equipment and residues from excess water from wells (“produced water”) • The Safety Guide offers recommendations for actions, procedures etc. that should be adopted • The Safety Report contains details of good practices with practical examples NSRW/WSS

15. IAEA work on NORM waste Guidance • The issue of Management and Regulation of Wastes containing NORM is now under active consideration • The intention is to concentrate on safety issues for the public and the environment in relation to waste containing NORM • NORM waste management may be a practice, an intervention or both! i.e. arising from a current activity, an “orphan activity’, or both on the same site • DS352 Safe Management of Waste containing Naturally Occurring Radioactive Materials (NORM) is in preparation and will be a Safety Guide • This document is aimed at providing Safety Guidance in relation to regulation of residues that contain NORM and improving safety and protection for the public and the environment in the management of such material NSRW/WSS

16. DS 352 • The draft proposal was approved by WASSC and RASSC and was finally approved for development by the Commission on Safety Standards (CSS) in November 2004 • The first consultant meeting was held in Vienna, March 2005 • The consultants had access to all the relevant reports and documents from IAEA, ICRP and the EU in addition to their own specialized knowledge • The first draft is currently in editing for submission to the Steering Committee in July or August 2005 • According to the production schedule, the final submission to CSS for endorsement is scheduled for June 2007 with publication anticipated in December 2007 • The consultants also had access to the outcomes of the Technical Meeting held in Vienna in December 2004 NSRW/WSS

17. Regulatory & Management Approaches for the Control of NORM residuesTechnical Meeting, Vienna 6-14 December 2004 • There were representatives from about 30 countries and organisations • Papers were presented by Country representatives on their national situations • These illustrated the wide range of materials involved and the inconsistencies in regulatory and management approaches • Working groups looked at 4 topics: Regulatory Issues Practical Solutions Public perceptions Waste and Product Safety and Management NSRW/WSS

18. Meeting Outcomes Main recommendations • Training and Guidance sought from Agency to settle inconsistencies and help manage issues of re-use and recycling “Concentrate and contain” v “dilute and disperse” What is a waste? Is that permanent? What about re-use of materials? How about building materials? • Agency assistance needed in formulating public awareness materials and in exchanging of experiences and information for practical solutions to problems e.g. cleaning up sites NSRW/WSS

19. Transporting NORM • July 2003 - Vienna • International Conference on the Safety of Transport of Radioactive Material • Amongst the issues identified and discussed were: • The applicability of the Transport Regulations to NORM • A decision that additional research was needed to relieve unnecessary burden of regulation in the matter of transporting very low level activity NORM NSRW/WSS

20. Transport Regulations for NORM • Previous exemption was 70Bq/g. • Modified by inclusion radionuclide specific levels in 1996 IAEA Transport Regulations (amended 2003) • This change brought bulk materials e.g. ores, tailings and backfill materials from some mining operations under the regulations • 1996 regulations allowed for a factor of 10 times higher than exemption quantities for NORM provided they are not intended for processing to extract radioactive components • However, this is potentially inconsistent with the developing scope of regulatory control set out in RS-G-1.7 • Consequently the full impact of the “factor of 10” is being researched under a Cooperative Research Project (CRP) which began in March 2004 The Regulations may be revised in the light of the CRP outcomes in respect of the packaging and transport of NORM NSRW/WSS

21. NORM related activities • The Agency is working to identify those work activities that may require control. • Training packages have been developed for • NORM Waste Management in relation to Mineral Industries • Radiation Protection and NORM Waste Management for the oil and gas industry • Training courses are underway at the regional and interregional level (mostly for regulators) • Future training for occupational radiation protection in mining and raw materials processing is in preparation NSRW/WSS

22. SUMMARY NORM is a topic that is fast becoming of significance to a wide range of industries previously not thought of as having a radiation protection requirement The Agency is working on a number of initiatives to provide both general and industry specific guidance for the safe management of NORM related practices and the waste that may be associated with these activities, including interventions A series of training modules to cover both radiation protection and waste management aspects of these issues are either in use or being prepared It is possible that some industries, or at least parts of them, may need to be controlled by radiation regulating authorities Before this happens there will need to be a carefully structured effort to inform the public and the workforce of the real situation The long term objective must be to provide allow industry to continue to operate safely and effectively whilst ensuring that the desired goals of long term safety and protection for the workforce, the public and the environment are achieved NSRW/WSS