[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
RE: CRCPD Regulations for TENORM
Dear RADsafers,
Let me (as I was out of the office for a while) react as yet on Al
Tschaeche's mail on the CRCPD TENORM regulations and some replies to this
note.
NEED FOR SUCH REGULATIONS:
In my opinion there is certainly a need for such regulations. I am aware,
that within the population of gas/oil industry workers there is a lot of
commotion about the 'natural' phenomenon of encountering (TE)NORM. Therefore
such regulations may be 'beneficial', both for workers - knowing the
achieved state of protection - and industry - able to demonstrate compliance
- . However, the exempt levels, which are 'borrowed' from the Uranium Mill
Tailings Radiation Control Act (UMTRCA) are extremely low (vide infra).
ACTUAL HARM DONE:
To my knowledge there are no reports (apart from some law suits, in which
lawyers were able to 'demonstrate' that harm was done to their clients)
actually stating the harm done to people. As doses to be expected from
industries exploiting natural resources all will be in the region, where
only stochastic effects may occur. Apart from the ores exploited in the
nuclear fuel cycle, the highest doses (up to about 100 milli-sievert per
year) received due to processing natural resources have to my knowledge been
in the mineral sands industry. These doses were much more common in those
days that the radiological impact of the (TE)NORM issues was not yet fully
recognised. Since the time radiation safety measures were imposed, these
doses were controlled and reduced considerably to well below the effective
dose limit for radiation workers (20 milli-sievert per year, ICRP-60). (To
my knowledge) for the gas/oil industry no major study has been carried out
into radiation doses received due to (TE)NORM. However, from the sparse data
available, it seems that doses (in uncontrolled situation) up to about
natural background levels (2 milli-sievert per year) may be received. By
imposing simple standard operational procedures (SOP's) these levels may
easily be controlled and reduced too below 100 micro-sievert per year.
'NUCLEAR AFFILIATION':
Nick Tsurikov pled for a non-nuclear affiliation for naturally occurring
materials. I can agree with this point of view. However, by using the term
non-nuclear industries, in my opinion the link to nuclear is already made
(and the word 'nuclear' is infected within the layman's world, as we know,
it was a major reason to rename a medical visualisation technique like
Nuclear Magnetic Resonance Imaging [NMRI] into MRI). I think a term like
'natural (geo)resources exploiting industries' completely avoiding the world
nuclear would be better. In principle Nick's plea addresses our major
communication 'problem' with society: How do we explain what we are
doing/protecting in clear and crisp language, which can be understood and is
trusted by the layman.
I noticed already some nice attempts on the WWW, but all still suffered from
their length or from too much scientific terms. Anyone, who has a good
layman's guide for TENORM or just radiation protection, please share the
information with the RADsafe community.
Some Thoughts/Comments CRCPD (proposed) TENORM Regulations:
QUOTE
definition of TENORM -
"Technologically Enhanced Naturally Occurring Radioactive Material" or
"TENORM" means naturally occurring materials not regulated under the Atomic
Energy Act whose radionuclide concentrations have been increased by or as a
result of human practices. TENORM does not include the natural
radioactivity of rocks or soils, or background radiation, but instead refers
to materials whose radioactivity is technologically enhanced by controllable
practices (or by past human practices).
rationale of TENORM definition -
The term TENORM does not apply to radioactive material in its natural state,
such as in geological formations or soils, in which human activities have
not taken place to enhance the concentration of NORM. It is recognized that
human activities involving NORM may enhance radiation exposure pathways
through redistribution (e.g. bringing subsurface NORM to the surface). The
CRCPD does not believe that such activities should fall within the scope of
these regulations. Inclusion of such practices results in regulation of
radiation exposures that could be equivalent to those resulting from
exposure to surface exposed mineralized land. The CRCPD is aware of federal
and state regulations that may address these concerns by requiring
reclamation of mined areas.
The definition of TENORM includes both physical and chemical processes that
enhance NORM concentrations above their natural state. TENORM was selected
over CENORM to ensure that physical processes that increase NORM
concentrations are included when they warrant regulatory oversight due to
their potential health risks. Examples of physical process that may warrant
regulatory oversight under Part N include (without limitation) gravimetric
separation, mechanical separation, dissolution and redeposition. Part N
provides mechanisms for generators to demonstrate that their physically
enhanced TENORM deserves exclusion from licensure.
UNQUOTE
As also addressed in Al Tschaeche's last mail (6-dec-98) this definition may
give rise to considerations: for the gas/oil industry this would imply that
the saline water with dissolved radium-ions ("production water"), which is
commonly accompanying gas/oil production, can be classified as naturally
occurring (the dissolution of ions is not enhanced by gas/oil production)
and consequently will be exempt from the CRCPD proposed regulations - just
mere transport from fluids from the gas/oil reservoir to the surface
facilities. Due to changes in temperature or pressure due to the
(technological) gas/oil production process calcium/barium/strontium (with
co-precipitated radium) sulphate/carbonate scales may deposit as hard
brittle material inside the vertical pipelines ('tubulars'). This material
would be subject to the TENORM regulations.
The CRCPD approach more or less seems a pragmatic attempt to regulate
naturally occurring radioactive materials. However, as already indicated by
Al the 'regulatory disputation arena' will move underground, by proving what
activity stems from a natural process and what is caused by human (or
technological) activities. In order to give you a taste of naturally
occurring radionuclides [NOR's] and concentrations encounter I provide you
with the following data from an external (and internal) extensive literature
survey. Note that all data refer to reported ranges and as there were no
data on the amount of samples available, and also samples with no NOR's were
not included no mean values can be derived from these tables (best in
non-scalable font).
GAS/OIL INDUSTRY PRODUCTS
CRUDE OIL [becquerel per gramme]
U-238 0.0000001 <> 0.01
Ra-226 0.0001 <> 0.04
Po-210 0 <> 0.01
Th-232 0.00003 <> 0.002
NATURAL GAS [becquerel per cubic metre]
Rn-222 5 <> 200,000
Pb-210 0.005 <> 0.02
Po-210 0.002 <> 0.08
"LIGHT" CRUDE OIL - 'NATURAL GAS LIQUIDS' NGL [becquerel per litre]
Rn-222 0.01 <> 1,500 in NGL as produced
Rn-222 0.01 <> 4,200 in propane [C3] fraction during
processing
Pb-210 0.3 <> 230
Po-210 0.3 <> 100
GAS/OIL INDUSTRY WASTE STREAMS
"PRODUCTION WATER" [becquerel per litre]
U-238 0.0003 <> 0.1
Ra-226 0.002 <> 1,200
Pb-210 0.05 <> 190
Th-232 0.0003 <> 0.001
Ra-228 0.3 <> 180
Ra-224 0.5 <> 40
"LOW SPECIFIC ACTIVITY" (LSA) SCALES from production tubing [becquerel per
gramme]
U-238 0.001 <> 0.5
Ra-226 0.1 <> 15,000
Pb-210 0.02 <> 75
Po-210 0.02 <> 1.5
Th-232 0.001 <> 0.002
Ra-228 0.05 <> 2,800
LSA SLUDGES from surface facilities [becquerel per gramme]
U-238 0.005 <> 0.01
Ra-226 0.05 <> 800
Pb-210 0.1 <> 1,300
Po-210 0.004 <> 160
Th-232 0.002 <> 0.01
Ra-228 0.5 <> 50
GAS/OIL INDUSTRY EXTERNAL RADIATION LEVELS [micro-sievert per hour]
Crude oil processing/treating
down hole tubing, safety valves (inside) < 300
well heads, production manifolds 0.1 <> 2.5
production lines 0.3 <> 4
separator scale (measured inside) < 200
separator scale < 15
water outlets up to 0.2 <> 0.5
Associated/Natural Gas processing/treating
downhole tubing 0.1 <> 2.2
piping, filters, storage tanks, reflux lines < 80
sludge pits, brine disposal/injection wells,
& brine storage tanks < 50
NGL processing
filters < 90
NGL pump < 200
C3 storage tanks < 60
NGL/C3 shipping pumps, C3 reflux pumps,
elbows & flanges 0.1 <> 2.8
CRCPD Exempt Level:
Proposed Exempt Concentration Level:
At first, I do interpret the term "Exempt Level" being applicable to
materials that are exempt from any regulatory control (correct me if I am
wrong). The CRCPD proposed exempt level (if maintained) of 5 pCi[NOR]/g or
0.185 Bq[NOR]/g is not too far above natural background levels. Applying the
Dose Conversion Coefficient of ICRP-72, such a level for radium-226 - which
is the most prominent NOR in gas/oil field scales - corresponds to 0.65
microSv/g[inhalation, adult, medium] or to 0.05 microSv/g[ingestion].
Projecting these numbers onto a risk scale exploiting ICRP-60 and the Linear
Non-Threshold relationship would result in a risk of 3E-8 [inhalation] or
3E-9 [ingestion] per gramme intake. These risks are extremely low compared
to risks normally encountered in our daily life.
Borrowing the 5 pCi[NOR]/g exempt level from UMTRCA does not do justice to
physical or chemical properties to materials, in which these NOR's are
encountered. For instance, gas/oil industry LSA scales are brittle and will
not leach in ordinary 'rain' water. In such a case, higher exempt levels
would (in my opinion) be acceptable. Besides, 'disposal' scenario's for oil
industry scales, may also be completely be different than those used for
uranium mill tailings. In short, much more industry focused exempt levels,
taking into account the characteristics of the TE(NORM) specific for that
industry, should be imposed. Another, regulatory tool might be 'clearance
levels' applicable to materials being under regulatory control, which might
be removed/disposed according (an authority) approved scenario. In such a
case, only notification will be required for application of the
removal/disposal method for materials below the 'clearance level'.
European Union (EU) Exempt Levels:
"The International Basic Safety Standards for Protection Against Ionising
Radiation and the Safety of Radiation Sources" as presented in 1996 in IAEA
Safety Series 115, provide an onset to more standardisation/comparability of
national regulations. As such the exempt levels presented in SS115 are also
included in EU Directive 96/29. All exempt levels have been derived from a
limited, standard set of labour/disposal scenario's, which were allowed to
deliver at maximum an individual dose of 10 micro-sievert, or a population
dose of 1 men-sievert at maximum. For NOR's the exempt levels are quoted in
sub-series form (which seems a reasonable approach to me), e.g. the U-238
series is broken down U-238+ (by definition U-238 till Pa-234m), U-234,
Th-230, Ra-226+ (Ra-226 till Po-214), Pb-210+ (Pb-210 till Po-210). To
accommodate for the precision of this approach exempt levels are quoted for
these sub-series as 10 to the power n, with n = 0 or 1 for exempt level NOR
concentrations (apart from Th-230, n = 1 for all U-238 sub-series). This
implies that an EU exempt limit will be higher more than 50 times higher
than the CRCPD proposed exempt level. The risk associated with 10
micro-sievert [5E-7] is still low compared to risks normally encountered in
our daily life.
Kind Regards, Gert Jonkers
CTAN - Analytical - Nuclear Measurement Techniques
http://sww.ksla.shell.nl/analytical/skills/nuclearmea/1.html
Radiotracer applications,
Gamma-transmission and Neutron BackScatter (NBS) measurements
Naturally Occurring Radioactive Materials (NORM)
Radiological Protection Advice
Shell Research and Technology Centre, Amsterdam (SRTCA),
http://www.srtca.shell.nl/welcome.html
PO Box 38000, NL-1030 BN Amsterdam, the Netherlands
tel. +31 - 20 - 630 3424
fax +31 - 20 - 630 2911
e-mail Gert.G.Jonkers@OPC.Shell.COM
> ----------
> From: Al Tschaeche[SMTP:antatnsu@pacbell.net]
> Sent: 1998-12-02 00:45
> To: Multiple recipients of list
> Subject: CRCPD Regulations for TENORM
>
> I just finished reading Part N, Regulation and Licensing of Technically
> Enhanced Naturally Occurring Radioactive Materials (TENORM) and the
> Rationale for that regulation. In neither of those documents do I find
> any discussion of why such regulation is needed. There are no data that
> I know of that show humans are harmed by current practices vis-a-vis
> TENORM. Does anyone out there know of documentation demonstrating that
> such regulations are needed to improve radiation health and that actual
> harm has been done to humans because there have been no such
> regulations? If so, would you be so kind as to point me to those
> documents (hopefully on the web so I can download them)? Thanks. Al
> Tschaeche antatnsu@pacbell.net
> ************************************************************************
> The RADSAFE Frequently Asked Questions list, archives and subscription
> information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html
>
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html