“Cradle to Grave” NORM Management Workshop

September 22, 2019

NORM Packaging/Transport/Disposal Options

US-International Transportation & Disposal Guidance & Regulations

“Cradle to Grave” NORM Management Workshop

Overseen by the IAEA (incorporated in the UN Model Regulations for Dangerous Goods) IAEA (2018 Edition) No. SSR-6 (Rev 1) publication titled “Regulations for the Safe Transport of Radioactive Material.”UN Recommendations on the Transport of Dangerous Goods

International NORM Transportation

International Guiding Principles • Wastes must be disposed of in the country of origin unless no suitable disposal routes are available.

• The Basle Accord (160 countries), defines internationally binding rules regarding the permitting and control of exports and imports of hazardous wastes.

• Waste shipments require the consent of the country of origin, the country of destination and all transit countries.

• Waste shipments are subject to notification and permitting of the competent authorities in the countries involved. The competent authorities can, in principle, deny permission in part or completely

North America Specific NORM Regs• United States – US DOT - Hazardous Material Regulations (Trucking & Rail) and US NRC

• Mexico – Mexico Regulation for the Land Transport of Hazardous Materials & Wastes

• Canada – Canada Transportation of Dangerous Goods (TDG) Regulations

• Individual US State Regulations - NORM Specific (Requirements/Manifests)

• US Radioactive Material Transporter Licenses

Hazardous Material Regulations (HMR)Hazardous materials are regulated in order to: Prevent accidents, leaks and spills Help emergency responders Ensure that HAZMAT employees are aware of the hazards of materials they handle

UN NORM Material Classification The first step in the NORM shipping process is determining if the material being shipped meets the definition of radioactive material Class 7. Radioactive Material – means any material containing radionuclides where both the activity concentration and the total activity in the consignment exceed the exemption limits.

UN # Description

2910 Radioactive Material, excepted package – limited quantity of material

2912 Radioactive Material, low specific activity (LSA-I) non-fissile

3321 Radioactive Material, low specific activity (LSA-II) non-fissile

3322 Radioactive Material, low specific activity (LSA-III) non-fissile

2913 Radioactive Material, surface contaminated objects (SCO-I or SCO-II)

Negative perception of NORM and/or Class 7 radioactive materialConflicting requirements between IAEA & National regulations and/or between different national regulations A ship’s captain, a plane’s pilot and a port’s harbormaster have the “Right to Decline” any shipment or passage. NORM Definition Disparity

NORM Transport Difficulties

NORM Definition Disparity • From the US-EPA: "Naturally occurring radioactive materials that have been concentrated or exposed to the accessible environment as a result of human activities such as manufacturing, mineral extraction, or water processing.”

• From the IAEA: NORM is defined as “Radioactive material containing no significant amounts of radionuclides other than naturally occurring radionuclides”

IAEA NORM Definitions• NORM: Radioactive material containing no significant amounts of radionuclides other than naturally occurring radionuclides• NORM Residues: Material that remains from a process and comprises or is contaminated by naturally occurring radioactive material (NORM). • NORM waste: Naturally occurring radioactive material for which no further use is foreseen.

Therefore, a NORM residue may - or may not - be waste. Source IAEA Safety Glossary 2007 Edition

US DOT Exemption for NORM49CFR173.401, Subpart I, titled “Class 7 (Radioactive) Materials” states that NORM waste from processes do not apply to:

Natural material and ores containing naturally occurring radionuclides which are not intended to be processed for use of these radionuclides, provided the activity concentration of the material does not exceed 10 times the values specified in the Table in 49CFR173.436.

Guidance from USDOT representatives indicate that NORM/TENORM waste does not apply to this exemption

US NRC Revised Rule (Effective 7/13/2015)

Although the USDOT governs transportation, the USNRC regulates the transportation of radioactive material under part 71. For NRC Licensed Operations

The USNRC revised the USDOT regulations to come into harmony with the IAEA's “Regulations for the Safe Transport of Radioactive Material” (TS-R-1) .

CFR Part 71.14 “Exemption for low-level materials” (10 X Rule) affects the previous limit established by the USDOT

Activity Concentrations for Exempt Material and Activity Limits for an Exempt Consignment Value

Radionuclide

Activity Concentrationfor Exempt Material-

Bq/g (pCi/g)

Activity Limit for an Exempt Consignment

µBq (µCi)

Ra-226 10 (270) 0.01 (0.27)

Ra-228 10 (270) 0.1 (2.7)

Th-228 1 (27) 0.01 (0.27)

Pb-210 100 (270) 0.01 (0.27)

US DOT Exempt NORM Limits

It is important to note that the regulations do not define radioactive material for shipping purposes based on radiation levels.

Activity Concentrations for Exempt Material and Activity Limits for an Exempt Consignment Value

Radionuclide

Activity Concentrationfor Exempt Material-

Bq/g (pCi/g)

Activity Limit for an Exempt Consignment

µBq (µCi)

Ra-226 100 (2700) 0.1 (2.7)

Ra-228 100 (2700) 1 (27)

Th-228 10 (270) 0.1 (2.7)

Pb-210 100 (2700) 0.1 (2.7)

IAEA Exempt NORM Limits (10 X Rule)

IAEA “Regulations for the Safe Transport of Radioactive Material” allow NORM waste from processes to take advantage of the 10 X Rule

Radiochemical Analysis

NORM Packaging

“Cradle to Grave” NORM Management Workshop

NORM Packaging DecisionsNORM packaging decisions should include the following criteria and conditions:

• Based on the Hazard of the Contents• Storage/Staging Environmental Conditions• Storage/Staging Time• Transport Requirements• Disposal Offloading Requirements • Waste/Material/Equipment Transport Options

The aim is always to ensure that there is no escape of material during transport, therefore checks should be made that seals are intact and lids fit correctly.

Strong Tight ContainerRequirements for most “Exclusive Use” Shipments require a “Strong, Tight Container”. Designed to survive normal transportation handling. In essence, if the material makes it from point X to point Y without being released, the package was a strong tight container.

Type A PackagingDesigned to survive normal transportation handling and minor accidents

Must have the ability to survive serious accident damage testsType B Packaging

Bulk Packaging

Training• Consignors must ensure affected employees understand the hazards.

• General awareness training should be provided to all personnel involved.

• Training may be needed for drivers, ship’s Captains, etc.

• US DOT requires Hazmat employees to receive DOT hazmat training every 3 years

Labeling • Labeling is the responsibility of the consignor and must take account of the latest IAEA standards and/or local Regulations.

• Where equipment is unpackaged shipping labels must still be attached to the item, its cradle, or its lifting device.

Notifications/Licensing • Some countries require vessels to be licensed to carry radioactive material.

• Notification/agreements to ship will be required by the receiving site, and other local requirements (24 hr notification given to a harbor authority)

Records • Description of shipment • No. of items/packages • Weight/volume • ID of isotopes and activity• Transport route, destination & authorization from the facility.

• Shipping paperwork • Any other relevant information

Contingency Plan• A written contingency plan must be available, defining the actions to be taken in the event of an incident during the transport of NORM.

NORM Transport (Land/Water/Air)

“Cradle to Grave” NORM Management Workshop

Road Transport

Rail Transport

Marine TransportationUS Waters

Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) – US Offshore Transportation

International WatersInternational Maritime Dangerous Goods Code (IMDG Code) - Outside US territorial waters

Air TransportationCommercial AirDangerous Goods Regulations (International Air Transportation Association)International AirICAO Technical Instructions International Air Transport (International Civil Aviation Organization)

NORM Management & Storage

“Cradle to Grave” NORM Management Workshop

NORM Management Options • Reprocessing• Repurposing• Re-Use• Recycling• Restriction• Shielding• Delay/Decay • Dilute/Disperse• Processing/Concentration

• Mining Residual Rock• Reprocessing/Extraction • Construction

Recycling Residual Uses

Recycling Residual UsesPhosphogypsum

• Soil conditioner & soil amendment• Construction applications i.e. plasterboard• Additive to cement (2–5%) • Bedding material in road construction• Cover and liner material for conventional landfill disposal facility

• Marine applications such as coastal protection and artificial reefs for oyster production.

Recycling Residual UsesFurnace slag

• Landfill material • Construction material • Construction of roads and dams (copper smelting, iron and steel smelting, scrap metal recycling and elemental phosphorus production)

• Component of cement, concrete and bricks (smelting of iron and steel diluted with fly ash)

• Zinc smelter slag used as an abrasive medium for sandblasting.

Recycling Residual UsesRed mud (bauxite tailings)

• Processed to recover metals such as iron and titanium.

• Bricks used in the production of catalysts and ceramics

• Soil conditioner for landfill.

Soil Remediation• Bioremediation: Treatment of polluted soils using bacterium. • Thermal Soil Remediation: Heating/Evaporating hydrocarbon impurities.• Air Sparging: Air injected into a polluted soil to force out organic vapors.• Encapsulation: The process separates contaminants from soil by mixing the polluted soil with lime, cement, and concrete to prevent (restrict) the contaminants from spreading to clean soil.

Phytoremediation• Treatment of pollutants or waste (as in contaminated soil or groundwater) by the use of green plants that remove, degrade, or stabilize the undesirable substances (such as toxic metals)

NORM Disposal & Options

“Cradle to Grave” NORM Management Workshop

Destruction/Disposal Options• Smelting• Incineration• Encapsulation• Landfill• Deep Well Injection• Cavern Disposal• Sea/Geologic Formation Discharge

Smelting• Slag, the byproduct of iron-working processes such as smelting or smithing, can contain concentrated levels of Ra-226/228 or Pb-210.

• Copper slag can be used either as sandblast grit or an admixture in concrete.

Incineration• The main purpose: to reduce waste volume.• Incineration does not destroy metals or reduce radioactivity of wastes.

Plug & Abandonment – Encapsulated Waste

Landfill (US Subtitle D)

Landfill (US Subtitle C)

Fracking Injection

Deep Well Injection (Cap Rock)

Deep Well Injection (Salt Dome)

Offshore Formation Discharge

US Commercial NORM Disposal• Clean Harbors (Landfill) – Hazardous Waste (Not Exempt)• Ecoserv (Caprock Injection) – RCRA Exempt• Energy Solutions (Landfill) – Hazardous Waste (Not Exempt)• Lotus (Cavern Injection) – RCRA Exempt• Sabine (Caprock Injection) – RCRA Exempt• Trinity (Cavern Injection) – RCRA Exempt• US Ecology (Landfill) – Hazardous Waste (Not Exempt)• Waste Control Specialists (Landfill) – Hazardous Waste (Not Exempt)

• Other state licensed Subtitle D Landfills with limitations

World Commercial NORM Management • Waste Management • Clean Harbors • Veolia Group • Tervita Corporation • Stork • Secure Energy Services • Studsvik AB • Buckhorn Waste Services • Clym Environmental Svcs • Wergeland Halsvik AS• NOAH Holmestrand repository • Borge• Morvilliers (France)

Questions & Answers“Cradle to Grave” NORM Management Workshop

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