Management of NORM - English
Transcript of Management of NORM - English
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Management of Naturally OccurringRadioactive Material
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Procedure for Management of Naturally OccurringRadioactive Materials
ROO-ALL-HS-PRO-0109
Pictures are for illustration purposes only
Revision history
Revisionnumber
Date Brief description of change Prepared Checked ApprovedRumaila
approval
01 16/05/12 For client review and adjustment RC RS JL
02 12/06/12 Client changes RS
03 17/07/12 Client changes RS
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Table of contents1.0 Summary ................................................................................................................................. 42.0 Introduction ............................................................................................................................ 4
2.1 Intent and purpose ................................................................................................................... 42.2 Application ................................................................................................................................ 42.3 References, abbreviations and definitions ............................................................................... 4
3.0 Responsibilities...................................................................................................................... 53.1 Site Controller .......................................................................................................................... 53.2 Area Authority .......................................................................................................................... 53.3 Safety Advisor .......................................................................................................................... 53.4 Performing Authority ................................................................................................................ 63.5 Work party ................................................................................................................................ 6
4.0 Naturally occurring radioactive material ............................................................................. 74.1 Naturally occurring radioactive material - general ................................................................... 74.2 Naturally occurring radioactive material - exposure and hazards ............................................ 84.3
Naturally occurring radioactive material (NORM) contaminated waste ................................... 9
4.4 Naturally occurring radioactive material f lowpath .................................................................. 114.5 Naturally occurring radioactive material local rules ............................................................... 124.6 NORM storage ....................................................................................................................... 144.7 NORM contaminated equipment ............................................................................................ 154.8 NORM decontamination ......................................................................................................... 15
5.0 Personal Protective Equipment .......................................................................................... 185.1 Personal Protective Equipment - general .............................................................................. 185.2 Radiation barrier tape and signs ............................................................................................ 19
Appendix 1 - Training, competence and authorisation ............................................................................. 20Appendix 2 - Compliance and auditing ....................................................................................................... 21
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1.0 Summary
The crude oil produced at Rumaila facilities may contain a by-product of naturally occurring radioactivematerial. Uncontrolled activities associated with enhanced levels of naturally occurring radioactive materialcan contaminate the environment and pose a risk to personnel at the site. These risks can be alleviated by
the adoption of the controls described in this procedure. All personnel must work in compliance with thisprocedure which is part of the HSE Management system.
2.0 Introduction
2.1 Intent and purpose
The intent of this procedure is to define the responsibilities of Rumaila personnel and their contracted servicecompanies when working with and disposing of naturally occurring radioactive material (NORM).
The purpose of this guide is to define how to control, store and safely dispose of solid and liquid wastesproduced which contain naturally occurring radioactive material. The goal is to prevent oilfield workerexposure from inhalation and ingestion of NORM dust or particulate, and to help ensure that NORM-contaminated equipment is not sent out for repair, released for use or sold as scrap metal with the potentialto expose subsequent handlers or the public.
2.2 Application
The scope of this procedure is to ensure that work with naturally occurring radioactive material is carried outsafely and that specific measures will be taken to comply with statutory controls affecting:-
Work involving the processing, handling, use, holding, storage, transport, or disposal of naturallyoccurring radioactive material
The preparation of contingency plans to deal with accidents or incidents
This procedure is applicable to all Rumaila personnel involved with naturally occurring radioactive material at
any Rumaila facility.
2.3 References, abbreviations and definitions
2.3.1 Related documents
The following documents are related to the NORM procedure and you should refer to each document asnecessary.
Document number Title of procedure
ROO-ALL-HS-PRO-0001 Control of Work Manual
ROO-ALL-HS-PRO-0010 Confined Space Entry
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2.3.2 Abbreviations
The following abbreviations are used in this document.
Acronym Explanation
AA Area Authority
CoW Control of Work
HSE Health Safety Environment
HITRA Hazard Identification and Task Risk Assessment
PA Performing Authority
PPE Personal Protective Equipment
PVC Polyvinyl Chloride
SA Safety Advisor
3.0 Responsibilities
3.1 Site Controller
The Site Controller has overall responsibility for the health and safety of personnel at each site. The SiteController is also responsible for ensuring that all precautions and controls are implemented at his site whenany work involving naturally occurring radioactive material is being carried out.
(see Appendix 1 - Training, competence and authorisation)
3.2 Area Authority
The Area Authority (AA) is responsible for the area where naturally occurring radioactive material is located.
The Area Authority will ensure that all barriers are erected and measures are implemented to reduce therisks to as low as reasonably practicable (ALARP).
He is also responsible for:-
Ensuring the naturally occurring radioactive material area is clear of all non-essential personnel
Ensuring toolbox talk is conducted prior to work start
Ensuring that all precautions stated on the Permit are implemented
Ensuring that all personnel possess and use the required Personal Protective Equipment (PPE) andthat it is in a serviceable condition
3.3 Safety Advisor
The Safety Advisor (SA) shall assist the Area Authority (AA) and Site Controller in ensuring that allprecautions stated on the Permit are implemented.
The Safety Advisor (SA) is responsible for:-
Monitoring of the work area
Ensuring that safe working practices are being enforced at all times
(see Appendix 2 - Compliance and auditing)
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3.4 Performing Authority
The Performing Authority (PA) is the person actually carrying out the work or leading the work party.Performing Authorities are accountable for the safety of themselves, their work party and anyone impactedby their work.
Performing Authorities are responsible for:-
Being fully conversant with the work, the potential hazards and associated precautions
Carrying out the safe execution of assigned work
Briefing (toolbox talk) everyone in the work party in the potential hazards, precautions and conditionsapplicable to the work
Ensuring everyone concerned understands the task, the hazards and the precautions especiallywhere the work party is multi-lingual
Ensuring the Permit, HITRA and any other associated documentation is displayed at the work site,wherever practicable
3.5 Work party
A member of the work party is anyone who carries out work under the direction of the Performing Authority.They are responsible for:-
Signing the Permit to acknowledge that they have received and understood a suitable toolbox talk
Reporting all worksite problems immediately to the Performing Authority (PA)
Working under the terms and conditions specified for safe work when working with naturallyoccurring radioactive material
Alerting the Performing Authority on identifying where the conditions specified in the Permit cannotbe complied with
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4.0 Naturally occurring radioactive material
4.1 Naturally occurring radioactive material - general
Naturally occurring radioactive material is a natural component of our environment which is found ingeological formations (Figure 1). It is usually brought to the surface in produced water. As the waterapproaches the surface, temperature and pressure change causes radioactive elements to precipitate out ofthe liquid phase and form solids. Resulting scale and sludge may collect in piping and vessels in crude orwater separation systems. Radium is usually found in this type of naturally occurring radioactive materialcontamination.
Figure 1: The origins of naturally occurring radioactive material
Gas Sphere
Crude OilTank
Produced
Water Tank
Gas Oil Separator
NORM in Scale
NORM in Gas
NORM in Crude Oil
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Naturally occurring radioactive material also occurs in gas processing where radon gas brought to thesurface enters the gas production stream. As it decays, thin radioactive films may form on the inner surfacesof gas processing equipment (Figure 2).
Figure 2: Example of NORM contamination
4.2 Naturally occurring radioactive material - exposure and hazards
Radium 226 and Radium 228 are the principal radioisotopes associated with oil and gas fluids. Theseelements and daughter decay products emit alpha, gamma and beta radiation.
The most serious health hazard is the alpha radiation. Alpha particles consist of two protons and twoneutrons (essentially a helium nucleus without the electrons of a helium atom) with a charge of plus 2, andan atomic weight of 4, emitted in the decay of heavy elements. These tiny charged cannon balls do not
travel far but do serious damage to living cells they pass through (Figure 3). Human exposure may occurwhen contaminated dusts and sludge are inhaled or ingested (internal exposure) or when gamma radiationfrom surrounding equipment strikes the body (external exposure). When scale containing alpha emittersdries and becomes airborne as dust, alpha emitting particles can be inhaled deeply into the lungs of peoplein the area. Alpha radiation released in lung tissue can cause serious damage. Gamma and beta radiationalso released by NORM scale are relatively weak and present a much lower radiation hazard.
Figure 3: Naturally occurring radioactive materials exposure scenarios
Alpha
Beta
Gamma
Gamma
Gamma
Gamma
Gamma
SCALE DEPOSITEDIN A SALTWATERFLOWLINE
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4.2.1 Potential long-term health effects
Unprotected overexposure to radium and radium daughter contaminated dusts has been associated with anincreased risk of lung cancer and leukaemia. Most naturally occurring radioactive material taken into thebody is deposited in bones where it will reside for a long time. Radium will not clear from the body
significantly over time. For this reason, all exposures should be kept below recognised exposure standardsand unnecessary exposure to radiation should be minimised.
4.3 Naturally occurring radioactive material (NORM) contaminated waste
If any naturally occuring radioactiove material is suspected, contact the Rumaila Environmental team toobtain additional information and allow for the further evaluation of the material to determine if it is NORMand, if necessary, how to handle and dispose of the waste.
Naturally occurring radioactive contaminated materials exceeding 70 Becquerels per gram (70 Bq/gm) aresubject to:-
UN recommendations on the transport of dangerous goods requirement
International Maritime Dangerous Goods Code International Air Transport Association Dangerous Goods Regulations
Naturally occurring radioactive material contaminated wastes may include filters from contaminated processstreams, storage and transport tank scale or sludge, water separation tank sludge and well bore scale.
Naturally occurring radioactive material storage areas shall be separated from other materials and entryrestricted. The storage area requires periodic radiation surveys to ensure gamma levels are not increasingabove hazardous levels and/or site contamination is not occurring from leaking containers.
Production tubing contaminated with radioactive material scale shall be capped, labelled and stored. Pullingof well tubes should be performed to ensure that any sludge contained within is radioactive material free.
Other wastes should be barrelled, preferably plastic to prevent corrosion, labelled and stored.
Naturally occurring radioactive material contaminated wellhead tubing and equipment require special
handling procedures. After pulling the xmas tree and wellhead equipment:-
Blind flange all piping ends to ensure that any radioactive material scale does not fall out
Install closed end thread protectors on each end of pipe and tubular assembly pieces
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The pipe and equipment must remain with ends secured until they are transferred to a protected cleaningarea. The pipe and equipment must be labelled according to its level of activity when transporting.
Figure 4: Schematic of surveying for naturally occurring radioactive materials
NORM monitoring
required
Instrument/survey
procedureRecord survey
results
Report survey
results
Trainedpersonnelavailable?
Selectappropriatedetectors
Instrumentsin calibrationfunctioning?
Obtain workpermits
YES YES
Train personnel orcontact trained
personnel
NO
Send forrepair/calibration
Carry outbackground check
Returninstruments to
storage for re-useNO
Carry out survey
Instrumentcalibration records
YESInstrumentsin calibration
functioning?
Instrumentsin calibration
functioning?
Inform of surveyfindings
NO
Training record
NormalOperations
ControlledHazard
Safe disposaloptions
Documentation
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4.4 Naturally occurring radioactive material flowpath
The following flowpath (Figure 5) determines the actions to be taken if there is a potential risk of radiationexposure.
Figure 5: Naturally occurring radioactive material flowpath
Carry out initial radiation check on
breaking of containment and before
any work begins.
Use dosemeter & measure in Sv/hr
(microsieverts/hour)
Isthere the
potential for exposure
to radiation?
Reading is
less than 7.5 Sv/hr?
Reading is
less than 3.0 Sv/hr?
End
Controlled Area
Consult with RumailaRadiation protection
Supervisors
Proceed with work,
complying with Permit
End
Supervised area
Comply with themanagement of norm
local rules(see page 12)
Consult with RumailaRadiation protection
Supervisors
Is total estimatedexposure greater than 1 mSv/year
(1 millisievert/year)(dose x time)
No
No
No
Unsure
Yes
Yes
Yes
Yes
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Table 1 dose readings correspondence to allowed minimum exposure time per day per worker. Dose rateswill fall off rapidly with distance (using barriers and signs) and effective shielding (for example, high massmaterials and graphite).
Dose readings (Sv/hour) Maximum allowed exposure time (min/day)
3.5 130
4 115
5 90
6 75
7.5 60
Table 1: Dose readings
Note: For non-classifed workers (annual exposure < 1mSv)
4.5 Naturally occurring radioactive material local rules
The following are the operational steps which are to be taken for the safe management of naturally occurringradioactive material, which includes background measuring naturally occurring radioactive material levels.Personnel and equipment contamination checks before, during and after work involving naturally occurringradioactive material is carried out (Figure 6).
The implementation and control of this process is the responsibility of the Rumaila Environment team and
Site Controller at each site.
The Rumaila Control of Work (CoW) manual is to be referenced in conjunction with this procedure.
Any work which requires or may involve personnel coming into contact with naturally occurringradioactive material is to be planned and include a HITRA before the work commences
Agree with the site where the work is to be carried out that there will be no simultaneous operationsthat may affect or impact the safe working distance/controlled area for the naturally occurringradioactive material work
Prior to the work commencing the toolbox talk checklist is completed with the team assigned tocomplete the work. Only approved workers are permitted to work with naturally occurring radioactivematerial. This will include the barrier equipment and the following PPE:-
o Tyvek style coverallso Neoprene, Polyvinyl Chloride (PVC) or nitrile rubber gloves
o Half-face respirators with high-efficiency particulate air cartridges. These should be tested
for fito Quarter-face high efficiency particulate air disposable respirators
o During the work no personnel are permitted to eat or drink within the work area. Drinkingand eating can only happen once the worker has been checked for contamination and thepersonal protective equipment removed, bagged and sealed for disposal. Hygiene is veryimportant with the washing of hands and face being mandatory
Confined spaces and vessel entry procedures, equipment are to be used at all times
Only personnel who have dose badges are to handle the naturally occurring radioactive material forboth removal from vessels or other areas, and including transportation for disposal to the approveddisposal site
Prior to work commencing a background check is required around the vessel to confirm radiationlevels. This information has to be included in the Permit
The radiation meters are to be checked and calibrated against a test source
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Prepare the work area by barriering off the area with a suitable distance, 360 degrees around thevessel
Prior to opening inspection hatches or sludge traps, sufficient ground cover shall be placed belowthe item in the work area. The ground cover should be made of a plastic, waterproof type of materialcapable of withstanding the work activities involved without tearing or ripping. Alternatively, a
suitable drip-tray or catch-pan may be used. The ground cover should be sized to provide for thecontamination of leakage and waste and to allow ample room for related peripheral work
Signs in English are to be attached to the barrier stating:-
Danger NO ENTRY - Naturally occurring radioactive materials (NORM)
The barrier is to have a Sentry present to prevent unauthorised personnel from entering the area forthe entire duration of the work
Take samples from the vessel, via the drain valves, before opening the access flange to establishpossible radiation levels inside the vessel
If the samples taken indicate a possible high reading within the vessel, then the vessel should becleaned via steam. It is important that any waste fluid or solids are collected in suitable sealedcontainers and handled by the approved workers for disposal
Any dry material that is naturally occurring radioactive material which has been contaminated shouldbe wetted down to prevent the generation of airborne radioactive materials. Dry material should bewetted periodically throughout the maintenance work
Repeat the sampling process after cleaning of the vessel until such time as the radiation readingreaches the acceptable level
A reading is taken from within the vessel to confirm the radiation is low. Until this is confirmed nopersonnel are permitted to enter or work on the vessel from the outside
Openings of equipment or pipes that have internal naturally occurring radioactive materialcontamination should be sealed or wrapped by plastic or other suitable materials
All the approved workers are to be checked to confirm that their personal protective equipment fitscorrectly and is used. The workers are checked for contamination during/after working with thenaturally occurring radioactive material and after carrying out cleaning and washing of their hands
and face Obsolete naturally occurring radioactive material, contaminated pipes or equipment should be clearly
labelled as naturally occurring radioactive material contaminated materials and removed to adesignated storage area. The area should be labelled as containing radioactive materials andrestricted from the general public
All contaminated waste generated during maintenance should be drummed or put into containersand marked or labelled. Representative samples should be collected from the waste and analysedfor radioactivity
Once the work has been completed and the area is confirmed as being cleared of naturally occurringradioactive material, the naturally occurring radioactive material waste and equipment is bagged andsealed along with contaminated personal protective equipment. The waste is to be removed fromthe site by the approved team
Disposal has to be confirmed by a certificate, stamped and signed by the Site Controller and
naturally occurring radioactive material team leader Upon completion of the work the Permit is signed off as complete; the site has been left in a safe
condition with post work radiation levels being recorded on the Permit
Note: IF AT ANY TIME THE ABOVE STEPS ARE NOT FOLLOWED, THEN ALL WORK MUSTSTOP UNTIL THEY ARE IMPLEMENTED.
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Figure 6: Naturally occurring radioactive material contamination site control
4.6 NORM storage
Where naturally occurring radioactive material waste is required to be stored at a Rumaila facility, it shall bekept in a suitable container which shall comply with the following requirements.
The container:-
Shall be in a good condition with no visible indications of internal or external corrosion
Be made of a durable material that provides adequate containment of the waste during the storageperiod
Shall be made of, or lined with, materials that will not react with or be incompatible with the waste sothat the ability of the container is not impaired or compromised
Shall be resistant to degradation by ultra violet radiation
Shall be closed and sealed during storage, and practical to open and re-seal when it is necessary toadd or remove waste
Shall not be opened, handled or stored in a manner that may rupture the container or cause it to leak
Shall bear the radiation symbol and a label clearly indicating that it contains contaminated waste
Shall be resistant to normally expected range of temperature in storage environment
Shall be resistant to water ingress
Shall be stored in a dry environment to prevent corrosion
Shall be physically robust to prevent damage during transport
The storage location should be hard surfaced and bunded to prevent contamination ofground/surface water and the creation of contaminated land from any potential leaks/spills as aresult of incidents during storage period
Areas where containers of naturally occurring radioactive material waste are stored should be inspected on aregular basis. Containers should be inspected for signs of leakage, overall deterioration and properlabelling. Records of these inspections should be documented and properly maintained.
GroundCover
GroundCover
SpecialDrain
Washing facility andtowels
UsedPPE
Exit
NewPPE
Entrance
Extraction fan
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Where naturally occurring radioactive material waste is disposed of, records shall be maintained of thedisposal activities. They should include but are not limited to:-
Waste material description; for example, scale, sludge and scrapings
Volume of waste material
Mass Naturally occurring radioactive material level (activity per unit weight) of waste material
Methods of disposal
Disposal location
Organisation/facility where the naturally occurring radioactive material waste was generated
Any other relevant information
4.7 NORM contaminated equipment
The following are the minimum requirements for the control of NORM contaminated equipment at a Rumaila
facility. Equipment shall:-
Be decontaminated prior to release for unrestricted use
Be stored only in designated storage areas Be tagged or clearly marked as contaminated
Be handled only by employees trained in naturally occurring radioactive material hazards andwearing relevant protective personal equipment
Not to be sent for maintenance/repair to Rumaila workshops without informing the workshop that thecomponent is contaminated with naturally occurring radioactive material
Be disposed of only in an approved disposal facility
Be decontaminated only in an approved decontamination facility or according to an approveddecontamination protocol
Be stored in areas which are exclusively used for the storage of contaminated equipment
4.8 NORM decontamination
Decontamination of equipment which is naturally occurring radioactive material which is contaminated shouldbe undertaken in a controlled manner to ensure worker protection, prevent the spread of contamination, andto minimise the waste arising from the decontamination process.
High pressure water jetting may be used for decontamination. When high pressure water jetting is used, thefollowing are to be supplied:-
Changing facilities for workers
Operating areas to carry out the work
Handling/receiving areas
Strip down areas
Water jetting areas
Ventilation system Inspection of equipment
Monitoring of equipment
A mobile decontamination unit may be used. These utilise modified containers to provide containment forhigh pressure water jetting operations, and are fitted with drainage systems which direct water used in theoperation through a series of filters and back to the water jetting system, so the waste is continually re-circulated.
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The following are the types of portable areas that may be required at a Rumaila facility in the event ofnaturally occurring radioactive material contamination.
4.8.1 Handling area
This will be for:-
Checking the inventory/material being sent for decontamination
Carrying out radiation surveys of decontaminated equipment
Providing a segregation system to keep incoming dirty items separate from outgoing clean items
A quarantine area for items that require further decontamination
4.8.2 Strip down area
To allow components such as valves and wellheads to be stripped down.
1.1.1.1 Pressurised habitat enabling oxy-propane cutting and grinding of equipment
This is an area where airborne naturally occurring radioactive material contamination may occur andtherefore requires total containment with a filtered extract ventilation system. Workers will be required towear respiratory protective equipment in this area.
1.1.1.2 Water jetting area
This is an area where airborne naturally occurring radioactive material contamination may occur andtherefore requires total containment with a filtered extract ventilation system. In this area workers will berequired to wear respiratory protective equipment. The floor and surfaces should be capable of withstandingthe impact of high pressure water jetting.
1.1.1.3 Liquid recirculation system
All process liquid used in decontamination operations should be filtered and re-used. There should be no
connection to any external drainage system. The following three elements will be required in the system:-
Primary supply tank
Filter bank
Settling tank
The system needs to separate naturally occurring radioactive material contaminated sediment and oily wastematerial from the process water.
Water from the jet area will be circulated back to the system by an enclosed and doubly contained drainagesystem.
A leak detection system should be included in the water circulation system.
The settling tank should be able to be readily accessible and able to have any sediment removed/decantedinto waste containers. The system shall have capacity to allow the transfer of water from the settling tank toanother holding tank to allow sediment removal.
1.1.1.4 Control of equipment
An administrative system is required to control and track the progress of all equipment and componentsentering the decontamination facility.
Inspection of all equipment and components should be carried out on receipt. The status of the equipmentshould be logged and any damage not logged on the documentation should immediately be brought to theproponents attention. The component shall be quarantined pending further instruction from the proponent.
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1.1.1.5 Monitoring of equipment
NORM is initially evaluated by measuring the gamma radiation emitted. Although this measurement doesnot directly measure the more significant hazard of alpha and beta radiation from the material, themeasurement of gamma radiation serves as an index to the presence and degree of NORM contamination.
Clearance of contaminated equipment should only be carried out by trained operators and monitored by theSafety Adviser.
All monitoring equipment should be fully operational and within its calibration period. A check on theoperational status of all radiological monitoring equipment should be maintained (Figure 7).
An administrative system should be implemented to identify items which are naturally occurring radioactivematerial contaminated from those that have been cleaned.
Figure 7: Naturally occurring radioactive materials site
MANAGEMENT OF
NORMALLY OCCURING
RADIOACTIVE MATERIALS
DECONTAMINATION IN
PROGRESS
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5.0 Personal Protective Equipment
5.1 Personal Protective Equipment - general
Personnel must be protected from the inhalation and or ingestion of NORM dust and particulate from the dryscale or sludge found in contaminated tubular and equipment. The gamma radiation is a marker, indicatingthe possibility of alpha and/or beta radiation in the scale.
The following safety precautions will be taken when the potential for exposure to NORM particulate exists:-
Check the radiation dose rate level of all NORM sludge and scale coated equipment
Avoid direct contact with radioactive scale and solids whenever possible
Do not eat, drink, smoke, or chew tobacco in work areas where NORM equipment is being surveyedor handled
Wash thoroughly following any skin contact with NORM, particularly prior to eating, drinking,smoking, or chewing
Cover openings of contaminated pipe and equipment with thread protectors or other suitablecoverings
Use plastic ground covers when performing maintenance to facilitate clean-up operations andprevent contaminating the ground
Keep NORM contaminated material damp or wet when possible to minimize the generation ofairborne radioactive materials
Use appropriate PPE when NORM contamination of the workers clothing and person could resultfrom working with or handling the NORM contaminated tubular or equipment. The PPE is not toprotect against the gamma radiation, which is simply a marker for the presence of NORM in theequipment. The PPE will protect workers from the particulates that contain alpha and beta radiation
that can enter the body to cause damage
PPE includes:-
Tyvek or other brand disposable suit Disposable gloves to keep dust off hands
Half mask or full face respirator with P-100 filter.
Workers who have handled NORM contaminated items must wash hands thoroughly at the end ofthe task, and shower at the end of the work shift
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5.2 Radiation barrier tape and signs
All radiological areas are identified by one or more of the following types of signs:-
Yellow signs with standard radiation symbol in magenta or black (Figure 8)
Yellow or magenta rope, tape, chains or other barriers (Figure 9) Yellow tags and labels with the standard radiation symbol in magenta or black
Figure 8: Radiation warning tape Figure 9: Radiation warning sign
CAUTION
RADIATION
AREA
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Appendix 1 - Training, competence and authorisation
All personnel directly involved with handling of radioactive material shall have received training in thepractical application of this procedure.
The training will include:-
Awareness of the hazards associated with naturally occurring radioactive material
The controls that are required for their protection
The methods for preventing human exposure and environmental contamination
How to handle storage and disposal of NORM
Training shall focus on operational personnel who are potentially exposed to naturally occurring radioactivematerial and directly involved in maintenance operations. The training will permit them to ensure that thework they do pays due regard to the hazards of naturally occurring radioactive material and prevents thespread of naturally occurring radioactive material contamination.
Personnel will require refresher training under any of the following conditions:-
Changes in the workplace render previous training obsolete
Legislation for naturally occurring radioactive material is amended or changed
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Appendix 2 - Compliance and auditing
It is essential that complete records are maintained of all naturally occurring radioactive materials found anddisposed of at Rumaila facilities. The Environmental Department will maintain these records.
The following information will be held:-
Naturally occurring radioactive material records
Records will be kept at the facility for at least two years before they can be archived.
Archived records will be kept for the lifetime of the facility.