1. Managing NORM - Oman and Regional Issues
Brett Young
This paper introduces attendees to local and regional issues faced by HSE professionals concerned with the Management of NORM from E&P activities. In many countries including Oman, specific NORM legislation does not exist. There is a lack of awareness of this emerging issue within the region from Ministries/Govt Officials, E&P contractors and inconsistencies between how the various E&P organisations manage NORM although they may operate under the one Shell banner. This paper asks more questions than provides answers, with the aim to provoke attendees to consider their own situation and discuss how to resolve these inconsistencies.

2. PDO Concession Area Northern Assets (OND) 1. LEKHWAIR 2. FAHUD
U.A.E.
PDO Concession Area
Northern Assets (OND)
1. LEKHWAIR
2. FAHUD
3. QARN ALAM
4. YIBAL
Southern Assets (OSD)
5. BAHJA
6. NIMR 7. MARMUL
Red – oil lines
Green – gas lines
Saudi Arabia
Crude - 650,000 Barrels per annum
Gas -

3. Ministry of Regional Municipalities & Environment. 6 JULY 1997
MINISTERIAL DECISION No. 249/97 Regulations for the Control and Management of Radioactive Materials
Ministry of Regional Municipalities & Environment.
6 JULY 1997
From a public
health perspective, efforts to limit exposure to NORM will have a far greater impact than introducing more
stringent requirements to control the use of licensed radioactive materials or nuclear power stations.

4. Definition
Radioactive materials: Any material with an activity concentration > 100 Bq/g. (Assume total activity)
Prior to mid 2004 PDO considered material below regulatory limits (i.e. non contaminated) when the activity was < 100 Bq/g
Supervised Area: An area where the immediate dose rates exceed 2.5 uSv/h uSv/h.
Controlled Area: An area where immediate dose rates can exceed 7.5 uSv/h
Classified worker: A person working in a controlled area which ensures that the person will not receive an annual dose exceeding 10mSv.
Package / Labelling / Transport - IAEA Regulations for the Safe Transportation of Radioactive Materials.

5. Sample Analysis PDO Sludge Sample ID 636 Ra-226 (x 6) 5.89 ± 0.09
Pb (x 3)
8.17 ± 1.45
Ra (x 2)
1.70 ± 0.02
Th (x 7)
3.61 ± 0.67
K-40
0.267 ± 0.040
*Calc. Max. Activity Conc.
88.5
**44A CPS to K40
0.3
PDO Contaminated Material Formula:
Total Activity = (6 x Ra-226) + (3 x Pb-210) + (2 x Ac-228) + (7 x Th – 228)

6. Contaminated Sludge
Six of seven Assets have NORM contaminated sludge > 1 Bq/g in the open, spread out in rows
Classification
Tonne %
Isotopic activity > 1 Bq/g (Ra-226) & > 5cps
7681
2.3
Isotopic activity > 2 Bq/g (Ra-226) & > 5cps
6660
2.0
Isotopic activity > 5 Bq/g (Ra-226) & > 5cps
2713
0.8

7. Local Issues No local legislation &/or guidelines for NORM
Limited expertise within Oman/PDO/Ministry
Limited enforcement from Ministries
Limited risk of litigation under Common law
Australia, Canada, US, UK all have specific legislation and guidelines
Health Issues driven by common law litigation not by health related risks e.g. smoking, asbestos.

8. Local Issues cont. Predominant Contractor workforce
E.g. tank cleaning, well workovers, pigging, plant maintenance, sludge farming.
PDO contractors with no/limited experience with managing NORM
Theft of equipment (potentially contaminated)
What are the other E&P contractors in Oman doing with their contaminated plant?

9. Local Issues cont.
Health not seen as a priority (Engineering/Safety focus)
Illnesses manifest for years (not seen in stats)
Worker develops lung cancer - how do we determine if illness was caused by work, genetic predisposition, lifestyle habits e.g. smoking
Potentially exposed workforce goes back to country of origin so there are no record of illnesses
There is no follow up of contract workers who leave Oman
If the inhalation of radionuclides is more hazardous than exposure to low doses, how much radionuclides can a person inhale?

10. Regional Issues Legislation - inconsistent or not developed
Transfer of contaminated equipment from one country to another e.g. esp’s
Religious issues
Climate
Lack of local/regional expertise
GCC Ministries combine resources and develop one set of legislation/Guidelines

11. What do I want to Know? Legislation, Guidelines & Standards
(Local versus International versus Shell)
Management Systems (consistency of approach)
Controls (workers and others)
Disposal of NORM
Decontamination of Equipment
What are the risks (health, reputation, litigation)
When can I/we sleep at night

12. Article 8
Any organization dealing with radioactive materials shall establish an internal management system including;
staff structure with well defined responsibilities,
written procedures of work,
quality assurance procedures,
staff training and
emergency procedures so as to meet the Ministry's requirements

13. Proposed Definition
NORM Contaminated material: Any material with an activity ≥ 1 Bq/g for Ra-226.
NORM Contaminated Equipment: Any item of plant which records > 5 cps above background