Managing NORM - Oman and Regional Issues Brett Young brett.young@pdo.co.om 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.

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 -

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.

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 - 7.5 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.

Sample Analysis PDO Sludge Sample ID 636 Ra-226 (x 6) 5.89 ± 0.09 Pb-210 (x 3) 8.17 ± 1.45 Ra-228 (x 2) 1.70 ± 0.02 Th-228 (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)

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

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.

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?

Local Issues cont. Health not seen as a priority (Engineering/Safety focus) Illnesses manifest for 15 - 20 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?

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

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

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

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