1. Engineering & Analytical - GSEA/4 “Problem Solving”
NORM Management System
(Shell Group HSE MS)
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
NL-1030 BN Amsterdam
the Netherlands

2. EXPLOIT ALL a priori KNOWLEDGE ON E&P NORM
FUEL GAS
GAS
SCRUBBER
1ST STAGE
SEPARATOR
FLARE
FLARE K.O.
DRUM
PRODUCTION
TUBING
OVERBOARD
PUMP
WATER FLOOD
INJECTION
SEA WATER
BOOSTER PUMP
DE-
AERATOR
SKIMMED
OIL PUMP
FLOTATION
CELL
METERING
PACKAGE
EXPORT
LINE
DEHYDRATOR
2ND STAGE
OIL SHIPPING
S.W.SERVICES
COOLERS ETC.
WELLHEADS
MANIFOLD

3. Effective Radiation Protection Programme
IAEA, Operational Radiation Protection - Safety Guides, Safety Series
IAEA, Recommendations for the Safe Use and Regulation of Radiation Sources in Industry, Medicine, Research and Teaching, Safety Series 102, 1990
Organisation
& Management
committed to
Safety & ALARP
Successful
Personnel
Selection
& Training
Effective
Occupational
Radiation
Control
Effective
Public
Radiation
Control
Effective
Emergency
Planning
& Preparedness
Implementation
Quality
Assurance
Effective Management Structure
Clearly Documented Authorities, Responsibilities, Job descriptions
Adequate resources
Commitment to Safety & ALARP from all Employees
Appropriate Selection Criteria
Complete Post-Appointment Training
Effective Control of Doses and Intakes
Adequate Control Standards
Effective Surveillance
Identification of Potential Sources of Public Exposure
Adequately Derived and Documented Criteria to Limit Public Exposure
Identification Potential Accident Situations
Evaluation Unidentified Accident Situations
Preparation Contingency Plans
Exercise Contingency Plans
Periodic Review Emergency Plans
Identification of Components Requiring Formal Quality Assurance
Identification of Applicable Standards
Adequate Appraisal Regimes
ad 1) documented qualification requirements for all levels, minimum age requirements, identified and documented medical requirements
ad 2) formal review training requirements, documented training objectives, adequate scope of training programme, induction training to rectify deficiencies
ad 1) adequate control of source, provision of physical barriers, provision of administrative controls
ad 2) adequately derived standards, adequately documented standards, pre-determined reference and action levels
ad 3) adequate monitoring of workplace, appropriate personal dosimetry, assessment of results and data of occupational radiation control
ad 1) adequate control of public doses due to
> accident situations,
> routine releases,
> transport of
radioactive materials,
> radioactive waste
ad 2) individual and collective doses
ad 1) equipment / procedure oriented
ad 2) satisfy self-determined / external / national standards
ad 3) defined appraisal committee / frequency of appraisals / scope of appraisals
ad 1) location, cause
ad 2) evaluation of non-radiological conseq./ hazard / personnel-at-risk / consequences
ad 3) statements potential situations & identifiable hazards, provision of adequate communicat., recommended course of action, availability emergency equipment, notifications outside organisation, plans for exposed personnel
ad 4) degree of involvement, frequency
ad 5) scope/frequency review
ad 1) adequate corporate/site structure, seniority safety management, safety independent of production
ad 2) production/safety: publish policies, clear organisation chart
ad 3) production/safety: competent staff, adequate facilities
ad 4) training, appraisal ratings include safety performance

4. Evolution of HSE Management Systems
Assurance
Safety
Safety
(HSE)
Management
System
Line
Management
Focus
Human Error
Focus
equipment
focus
1970
1980
1990
2000
1960
Past Present TRENDS
Safety engineers / officers Line management responsibility supported by safety (HSE) advisers
Reaction to accidents Prevention of accidents
Accidents accepted Accidents can severely erode the reputation/results of the Company
Prescriptive rules Goal setting rules risk based
Safety was a side issue HSE is a core issue

5. HSE Management System Structure DO
Leadership and Commitment
Policy and Strategic Objectives
PLAN
Organisation, Responsi-bilities, Resources, Standards and Documents
Hazards and Effects Management
Corrective
Action DO
Planning and Procedures
FEEDBACK
Implementation
Monitoring
Corrective Action and Improvement
Audit
CHECK
Corrective Action and Improvement
Management Review

6. Leadership & Commitment
Specific requirements for (E&P) NORM (draft)
Company Management shall ensure that extracted natural resources (e.g. Oil, Gas, Tar sands, Coal) are evaluated on NORM contents and that methods to reduce production are considered.
All persons that can potentially be exposed to NORM shall be informed.
Site owner shall assess the risk of NORM contained in feedstock or purchased materials based on extracted natural resources and minimize the quantities imported.
Site owner shall check and have an inventory of accumulations of NORM in company and contractor equipment.
Management to make sure that a qualified person is assigned to advice on dealing with the NORM. Accountability for managing NORM rests with site management.
Receivers of products and waste streams from contaminated installations shall be made aware of the NORM contents.
Company and contractor organisations maintaining or demolishing the installations shall be made aware of contaminations and the correct disposal route.
Emergency response plans shall deal with the reputation aspects of inadvertent handover or disposal of NORM containing product, equipment or waste

7. Potential Embedment of NORM (IR Protection) Know How
Company
Managing Director/Board
Radiation (NORM) Advisory Committee
Chair: HSE Manager
Members: Managers of “NORM-affected” operations (incl. contractors)
Company Radiation Focal Point
External
Radiation Protection Advisor
Operations Radiation Focal Point
Field/Asset Radiation Focal Points
Field/Asset HSE advisors (Radiation Protection Technicians)
(HSE critical activities)

8. Hazard and Effects Management Process (HEMP)
Identify
Are people, environment or assets exposed
to potential harm?
What are the causes and consequences?
How likely is loss of control?
What is the risk and is it ALARP?
Assess
Can the causes be eliminated?
What controls are needed?
How effective are the controls?
Control
Can potential consequences or effects be mitigated?
What recovery measures are needed?
Are recovery capabilities suitable and sufficient?
Recover

9. MODES OF (NATURAL) DECAY
222Rn Po + a
emission of mono-energetic, fast (MeV) He nuclei
214Pb Bi + b
emission of poly-energetic, fast (keV< >MeV) electrons hn
234mPa Pa + g
emission of mono-energetic, penetrative (keV< >MeV) photons

10. RADIATION PENETRATION CHARACTERISTICS

11. Dose Conversion Coefficient Radionuclide Specific
POTENTIAL EXPOSURE & ASSESSMENT
Inhalation (Bq/m3) airborne & radon contaminates body (lungs) g
Intake (Bq) & DCCinh (Sv/Bq):
internal dose (Sv)
Ingestion (Bq/L, Bq/g) contaminates body (stomach)
Intake (Bq) & DCCing (Bq/Sv):
internal dose (Sv)
Irradiation by g-photons
from outside the body
Dose rate (mSv/h) / exp. Time (h):
external dose (Sv)
surface dose rate (mSv/h per Bq/cm2) / exp. time (h):………
skin dose (Sv)
Contamination (Bq/cm2) of the outside body (skin)
Dose Conversion Coefficient
(Bq/Sv, ex ICRP #72)
Radionuclide Specific
Sum  whole body dose (Sv)

12. The Bow Tie model Top Event Control (keep within control limits)
CONSE
QUENCE
HAZARD
SCENARIO
Top Event
CONSE
QUENCE
THREAT
RECOVERY
PREPAREDNESS
MEASURES
CONSE
QUENCE
BARRIERS
Control (keep within control limits)
Prepare for emergencies
Objective: reduce likelihood
(pro-active/preventative)
Objective: mitigate consequences and re-instate (reactive)

13. Possible End Consequences from a Top Event
People
NORM no acute effects
chronic exposure
Environment
discharges to air & water; waste
Reputation

14. HSE Commitment and Risk Management
Target
tasks
responsibilities
competencies
procedures

15. FROM DOSE TO RISK LEVELS
Hazard Identification:
NORM exposure within in stochastic (chronic) dose regime, i.c. no deterministic (acute) effects
Epidemiological data shown conclusively that ionising radiation can cause cancer in human beings.
Dose-Response Relationship:
Absorbed dose in tissue is the physical fundamental quantity, that determines the response, NOT the source of radiation;
Estimates stem from special groups exposed well above natural levels, like Japanese bomb survivors, uranium miners, radium dial painters;
Linear function of dose without a threshold (LNT-model; UNSCEAR 5% per Sv).
Exposure Assessment:
Similar for (naturally occurring) radionuclides and other hazardous chemicals except that external exposure to penetrating radiation is an important pathway.
Risk Characterisation:
Relatively straightforward, and generally focuses on fatal cancers as the endpoint of concern (LNT-model; UNSCEAR = 5% per Sv adopted by ICRP).

16. Quantified Risk Assessment Levels (QRA)
Individual Risk Per Annum
10-3 die per year
10-6/y
10-4 die per year
10-5/year
Fundamental improve-ments needed. Only to be considered if there are no alternatives and people are well informed.
Intolerable
Too high, significant effort
required to improve.
natural background dose
The ALARP or Tolerable Risk
Region (Risk is tolerated only and risks have to be managed to ALARP)
High, investigate alternatives
public dose limit
NORM source constraint
Low, consider
cost effective alternatives
Broadly acceptable region.
Negligible, maintain normal precautions
practice source constraint
No need for detailed working
to demonstrate ALARP

17. Operations - External Radiation Hazard
TARGET Minimisation of Exposure to Penetrative Radiation Emitted by NORM Deposits
TIME Minimise the time spent in proximity of NORM affected facility parts.
DISTANCE Maximise the distance to NORM affected facility parts.
SHIELDING Maximise the shielding between personnel and NORM affected facility parts. g
Barriers
Separation (Time & Distance)
Administrative (Training, Warning)
Procedural g

18. Maintenance - Internal & External Radiation Hazard
TARGET Prevention of Internal Contamination by Naturally Occurring Radionuclides in Deposits (NORM)
Ingestion Avoid direct skin contact with LSA deposits. No eating, drinking etc. at the workplace. Use PPE (e.g. gloves).
Inhalation Avoid dust generating operations. Use PPE (e.g. respiratory protection).
External Time (Distance/Shielding) applies as well. j b a a b
Barriers
Separation (Time & Distance)
Administrative (Training, Warning)
Procedural
Repressive (ventilation, dust filtration) a b g

19. ABANDONMENT - Internal & External Radiation Hazard
TARGET Reducing both External and Internal Dose by Naturally Occurring Radionuclides in Deposits (NORM ) from former Gas/Oil Production Activities to an Acceptable Level for Future Inhabitants
Ingestion Determine amount of radioactivity entering food chain.
Inhalation Potential (topsoil) dust activity levels extremely low.
External (Sub)soil activity levels sufficient low. g
Barriers
Administrative (Training, Warning)
Procedural
Preventative (area cover, collection)
Repressive (ventilation, dust filtration)
Recovery Preparedness
Curative (cleanup, remediation)
Compensatory a b g

20. Review & Corrective Actions
Dose records and/or dose assessments, NORM surveys, NORM analysis results, NORM production (notification & licensing?) should be reviewed regularly by the Radiation Advisory Committee defining Corrective Actions for Improvement

21. SYSTEMATIC APPROACH TO PROTECTION AGAINST “NORM”
“OPERATIONS” NORM (external/contamination) radiation survey
dose readings > 0.5 mSv/h NORM contaminated
or contamination readings > 50  bg signpost areas
0.1 mSv/h < dose readings < 0.5 mSv/h NORM suspect
or 5  bg < contamination readings < 50  bg
dose readings < 0.1 mSv/h no NORM restrictions
and contamination readings < 5  bg
“MAINTENANCE” NORM (external/contamination) readings ad hoc
NORM contaminated: take external and contamination readings for open tanks/vessels, working hours, asses dose, Waste Storage
NORM suspect: take external and contamination readings for open tanks/vessels, record working times, take ‘representative’ sample
Analyse for final classification of waste: normal / NORM

22. Risk of Radiation Doses Compare with Natural Background Dose