what do workers in the field need to know about norm/tenorm

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What Do Workers in the Field Need to Know About NORM/TENORM Alan Fellman

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Page 1: What Do Workers in the Field Need to Know About NORM/TENORM

What Do Workers in the Field Need to Know About NORM/TENORM

Alan Fellman

Page 2: What Do Workers in the Field Need to Know About NORM/TENORM

What do Workers in the Field Need to Know About NORM/TENORM

Alan Fellman, Ph.D., C.H.P. Dade Moeller & Associates, Inc.

Page 3: What Do Workers in the Field Need to Know About NORM/TENORM

Outline

• Definitions • Sources and types of NORM/TENORM • NORM Regulations • Oil and Gas Industry NORM Wastes • NORM/TENORM Radiation Safety

December 2-3, 2014

Page 4: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 5: What Do Workers in the Field Need to Know About NORM/TENORM

Definitions NORM: Naturally Occurring Radioactive Material – U, Th, Ra, Rn, etc. or if you prefer: Cheers regular; loves beer

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

Page 6: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 7: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 8: What Do Workers in the Field Need to Know About NORM/TENORM

Background Radiation

People around the world are continually exposed to radiation from natural sources • These sources include:

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

Page 9: What Do Workers in the Field Need to Know About NORM/TENORM

Sources and Types of NORM/TENORM

• 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

Page 10: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 11: What Do Workers in the Field Need to Know About NORM/TENORM

NORM Contamination

• Radon gas, external exposure, internal exposure

• Potential: Worker exposure General public exposure (and associated

litigation risks) Environmental impact

December 2-3, 2014

Page 12: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 13: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 14: What Do Workers in the Field Need to Know About NORM/TENORM

Oil Field Waste

• NORM radionuclides may be concentrated in the oil recovery process 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

Page 15: What Do Workers in the Field Need to Know About NORM/TENORM

Oil Field Waste: Example Radionuclide Content

Average Sludge Average Scale Radionuclide pCi/g pCi/g

210Po 56 360 210Pb 56 360 226Ra 56 360 228Th 19 120 228Ra 19 120 Total: 206 1,320 Note: Typical radium-226 in soil is ~1 pCi/g * EPA Data

December 2-3, 2014

Page 16: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 17: What Do Workers in the Field Need to Know About NORM/TENORM

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?

Page 18: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 19: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 20: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 21: What Do Workers in the Field Need to Know About NORM/TENORM

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

Page 22: What Do Workers in the Field Need to Know About NORM/TENORM

Questions/Comments?

Contact Information: Alan Fellman (301) 990-6006 ext. 3302 [email protected]

December 2-3, 2014