1. What do Workers in the Field Need to Know About NORM/TENORM
Alan Fellman, Ph.D., C.H.P.
Dade Moeller & Associates, Inc.

2. Outline Definitions Sources and types of NORM/TENORM NORM Regulations
Oil and Gas Industry NORM Wastes
NORM/TENORM Radiation Safety
December 2-3, 2014

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. NORM Contamination Radon gas, external exposure, internal exposure
Potential:
Worker exposure
General public exposure (and associated litigation risks)
Environmental impact
December 2-3, 2014

11. 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

12. 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

13. 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

14. Oil Field Waste: Example Radionuclide Content
Average Sludge Average Scale
Radionuclide pCi/g pCi/g
210Po
210Pb
226Ra
228Th
228Ra
Total: ,320
Note: Typical radium-226 in soil is ~1 pCi/g
* EPA Data
December 2-3, 2014

15. 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

16. 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?

17. 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

18. 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

19. 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

20. 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

21. Questions/Comments?
Contact Information:
Alan Fellman
(301) ext
December 2-3, 2014