MSE CONTROLLED DOCUMENT

NORM Guidelines
Master Document

Document No: MSE.00 Custodian: MSE

Supersedes Revision no: 1
Revision no: 1 Filename: NORMMGT.
Date:1/10/2004 Date: 1/10/2006 DOC

Administered by: Verified: Date: Verified: Date: Approved: Date: Approved: Date:

MSE RPA OND/OSD

UWD/GD

Date: Date: Date: Date:

1/10/2004

Reason for revision:

This document contains proprietary information and is intended for use by PDO and Contractor staff
only. The contents of this controlled document shall not be changed without formal approval of the
document custodian.
 NORM Guidelines Master Document

Rev.1
Contents
1. Purpose of this document............................................................................. 2
2. Introduction.................................................................................................... 2
3. Policy.............................................................................................................. 3
3.1 Policy Statement..................................................................................................... 3
3.2 Policy implementation............................................................................................ 3
4. Organisation................................................................................................... 4
4.1 Structure................................................................................................................. 4
4.1.1 Radiation Advisory Committee (RAC)............................................................ 4
4.1.2 Radiation Protection Adviser (RPA)............................................................... 4
4.1.3 Radiation Protection Supervisor (RPS).......................................................... 5
4.1.4 Radiation Protection Technician (RPT).......................................................... 5
4.2 Tasks/ responsibilities............................................................................................ 5
4.2.1 Radiation Advisory Committee....................................................................... 5
4.2.2 Corporate Radiation Focal Point (CRFP)....................................................... 6
4.2.3 Radiation Protection Supervisor (RPS).......................................................... 6
4.2.4 Radiation Protection Technicians (RPT)........................................................ 6
4.3 Training................................................................................................................... 7
5. Recommended Radiation Dose Limits......................................................... 7
5.1 Dose limits.............................................................................................................. 7
5.2 Derived limits.......................................................................................................... 8
5.2.1 Dose rate limits............................................................................................... 8
5.2.2 Inhalation an/or Ingestion limits..................................................................... 8
5.2.3 Monitoring of personnel................................................................................. 9
6. Measurements............................................................................................... 9
6.1 Field measurements............................................................................................... 9
6.2 Laboratory measurements..................................................................................... 9
7. Protective measures...................................................................................... 10
8. NORM locations............................................................................................. 10
9. Registration.................................................................................................... 10
9.1 Register of radiological workers............................................................................ 10
9.2 Personal radiation dose records............................................................................ 10
9.3 Registration of ionising radiation sources............................................................. 11
9.4 NORM...................................................................................................................... 11
10. Storage, transport and disposal................................................................... 11
11. Emergency procedures................................................................................. 11
12 NORM procedures......................................................................................... 11
13. References..................................................................................................... 11

APPENDICES
Appendix 1 Glossary of Abbreviations........................................................................... 12
Appendix 2 List of NORM Guidelines.............................................................................. 13

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1. Purpose of this document
The purpose of this document is to lay down how the hazards of Ionising Radiation are managed
within Petroleum Development Oman (PDO).

2. Introduction

Exposure to ionising radiation may cause detrimental effects on the human body and in the long
term may lead to adverse health effects such as cancer or leukaemia. For these effects the severity
increases with the amount of radiation received and PDO has adopted a policy of reducing
exposures to as low as reasonably achievable (ALARA).

Examples of radioactive sources used by PDO and its contractors include: x-ray devices, well
logging tools, density gauges and multiphase flow meters. There are also natural occurring ionising
sources such as cosmic rays from the sun and naturally occurring radioactive elements such
as Uranium 235, Thorium 232 and Potassium 40. Everyone is exposed to naturally occurring
radioactive sources on a daily basis and even these vary from country to country and from region
to region. This is also true for Oman and the average background radiation due to terrestrial
radiation is 0.3 mSv per annum compared to the world average of 0.4 mSv per annum.

Unstable isotopes of Uranium, Thorium, radium and radon, for example, exist naturally and they
are referred to as Naturally Occurring Radioactive Materials (NORM). For these radioactive atoms
(also referred to as radionuclides or radioisotopes) to become more stable, the nuclei eject or
emit subatomic particles (alpha and/or beta) and high-energy photons (gamma rays). This process
is called radioactive decay.

NORM namely, Uranium-235 and Thorium-232, exist in the formation rock and were formed with
the creation of the earth millions of years ago. The parent elements uranium and thorium decay
to their daughter isotopes which are also radioactive. Uranium decays through a series to radium-
226 and thorium decays through its series to radium-228. The radium isotopes are water soluble
dissolve in the reservoir water in contact with the formation rock. When our production activities
extract reservoir water/oil, NORM (seen as Ra-226 and Ra-228) precipitates on the interior of
production equipment as scale (Barium/Radium Sulphate scale) and solids such sand/clay and silts
deposit with the oil in vessels and separators. Wax from pigging activities on the inside of pipes
may also contain some NORM and should be treated as contaminated until proven otherwise by
monitoring.

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3. Policy
3.1 Policy Statement
PDO will:
Protect its personnel, contractors, 3rd parties and the environment against the hazards of
exposure to ionising radiation due to PDO activities.
Avoid uncontrolled releases of radioactive contaminated substances and to minimise the
effects of past deposits
Apply the principles of ICRP 60 for radiation protection (justification of a practice,
optimisation of protection and dose & risk limitation)

No new practices shall be adopted without justification that they are of benefit
Keep exposure As Low As is Reasonably Achievable (ALARA) where exposure to ionising
radiation is not avoidable
Prevent any exposure to ionising radiation levels that result in an effective dose of more
han 1mSv/y above background to non-classified personnel and to the public

Avoid the need for classified radiological workers wherever reasonably practicable

3.2 Policy implementation

The following will apply:

Adherence to Policy

All activities with, or related to, ionising radiation sources are to be documented in procedures.
Adherence to these procedures will be audited.

Justification

Justifications for changes to established procedures, which involve exposure risks, are to be agreed
by the Radiation Advisory Committee (RAC).
Optimisation
Where exposure to Ionising Radiation is possible, measures need to be taken to keep the
exposure As Low As is Reasonably Achievable (ALARA). The RAC will provide further guidance
on reasonable achievability.
Procedure to be followed to deviate from policy
MSE is owner of Ionising Radiation Policy and, acting on recommendation of the RAC, has final
responsibility for authorising any modifications or deviations. Any deviations from the policy will
be documented in procedures.

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Specific objectives for NORM are:

To identify all sites where radioactive substances are present to:

implement suitable PPE when required
implement clean up efforts using a cost/benefit approach
prevent spreading of radioactive substances in the environment
treat, store and dispose of contaminated equipment and radioactive waste in a controlled
manner

4. Organisation
4.1 Structure
Five organisational entities advise on Ionising Radiation:
the Radiation Advisory Committee (RAC),
the Corporate Radiation Focal Point (CRFP)
the Radiation Protection Adviser (RPA),
the Radiation Protection Supervisor (RPS) and
the Radiation Protection Technician (RPT).

4.1.1 Radiation Advisory Committee (RAC)

The RAC sets PDOs policy with respect to Ionising Radiation. The RAC reports to the PDO MSE
Steering Committee and comprises:
OSD (Chairman),
MSE 32 (Secretary),
ONO1
OSO1
MSE23
On invitation representatives from drilling (UWD1)

The RAC reports to the PDO HSE Steering/Implementation Committee.

4.1.2 Radiation Protection Adviser (RPA)

The RPA is PDOs external expert on Ionising Radiation. He advices on policy proposals and
undertakes audits of PDOs radiation management system to ensure PDO is current with best

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practice on an international level. The RPA will be a source of expert advice for all matters
concerning Ionising Radiation.

PDO will use an external consultant as part-time RPA and utilise the experience within the
organisation to develop policy and procedures for managing ionising radiation.
4.1.3 Radiation Protection Supervisor (RPS)
Measurements and radiological assistance in supervision of work involving Ionising Radiation will be
done by Radiation Protection Supervisors (RPSs), Radiation Protection Technicians who will report
to the line. PDO does not currently have an experienced Senior Radiation Protection Supervisor.
The CRFP will act as representative on behalf of the RPA and will be based at Muscat.
4.1.4 Radiation Protection Technician (RPT)
To support the RPSs a number of employees (e.g. maintenance operators, MSE Advisors, Production
Supervisors, Campaign Supervisors) will be trained as Radiation Protection Technicians. RPT
Level is the minimum level of training required to conduct NORM Radiological Survey as part of
the PTW when a specific part of the installation is opened. The NORM Radiological Report is
then attached to the PTW for the Production Supervisor or Worksite Supervisor to interpret and
sign-off. The RPT adhere to the instructions of the Production Supervisor, Worksite Supervisor or
other permitted to authorise a PTW involving maintenance on plant that has conveyed reservoir
water/oil/gas.
4.2 Tasks/ responsibilities
4.2.1 Radiation Advisory Committee
The role of the RAC is listed. The roles of the RAC, the CRFP and the RPA are complementary.
The CRFP in consultation with the line puts forward proposals and the RAC decides on the course
of action with the advice from the RPA where necessary.

1. Leadership and commitment

1.1 Set priorities
1.2 Make resources available

2. Policy and strategic objectives

2.1 Compare standards, Oman and international legislation, and advice on standards to
be adopted.
2.2 Review policy statements

3. Organisation
3.1 Identify need for additional resources

4. Hazards and effects management

4.1 Evaluate radiological data
4.2 Identify risk-reducing measures
4.3 Set realistic objectives and performance criteria
4.4 Identify credible emergency events and identify response requirements and plans

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5. Planning and procedures
5.1 Review procedures with respect to Ionising Radiation every two years
6. Implementation, Monitoring, Corrective Action
6.1 Monitor compliance with the companys NORM policy and advise on corrective
actions
7. Audits
7.1 Ensure NORM is covered in MSE audits
7.2 Advise MSE with respect to audits on NORM (on request).
8. Management review
8.1 Ensure that NORM Management System is subject to management review

4.2.2 Corporate Radiation Focal Point (CRFP)

In addition to the tasks and responsibilities mentioned above, the CRFP or the RPS (see below)
shall:
be current on all potential and actual NORM-related activities within the company at all
times
ensure records/registers are kept on radiological workers, Ionising Radiation sources,
NORM measurements (count and dose rates, specific activity), radioactive waste, radioactive
contaminated equipment
act as secretary for the RAC meetings
identify the number of RPSs and RPTs required
audit implementation of the NORM management system
4.2.3 Radiation Protection Supervisor (RPS)
The RPSs will act as focal points for the CRFP and will maintain an overview of all radiological
activities in the interior. The RPSs will resolve queries on behalf of the CRFP.
The RPSs shall:
inspect and give radiological assistance in supervision of work involving ionising radiation
sources of a non-routine nature
ensure quality assurance of radiation protection
organise the required monitoring and sampling
qualify waste with respect to radioactivity
ensure that radioactive waste and NORM-contaminated equipment is stored, packaged,
transported and disposed off in compliance with regulations and procedures
communicate with and report to the CRFP
4.2.4 Radiation Protection Technicians (RPT)
The RPTs shall:
undertake NORM measurements whenever no data are available on installation parts to
be opened
register and report the results in compliance with the relevant NORM Procedure
notify the RPS/CRFP if count rates exceed the agreed standards
give radiological assistance in supervision of routine NORM jobs as agreed by the RAC

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4.3 Training
PDO have a suite of courses dedicated to NORM. The line shall develop and maintain a training
database specifying requirements per job. This includes training requirements for Contractors.

5. Recommended Radiation Dose Limits

5.1 Dose limits
The ICRP recommends that the exposure of individuals to radiation should be subject to dose limits.
The occupational dose limits are aimed at ensuring that no individual is exposed to unacceptable
risks as well as preventing any deterministic effects and minimising the chance of stochastic effects.
The natural background radiation, including radon, is excluded for the dose limitations. Radiation
doses arising from medical procedures are also excluded from the dose limitations.

Certain activities or job types within PDO have potential to expose workers to higher radiation
doses than others. PDO has adopted two dose limits for workers based on job types. These limits
are defined as Target and Maximum limits for workers likely to be exposed to NORM during the
course of their normal work activities.

The Target Limit is a dose that PDO believes all workers should not exceed on an annual basis.
Doses received by workers above the Target Limit indicate that controls may not be effective,
however workers can continue to work in their given job type provided the controls are reviewed
and the maximum dose limit is not reached.
The Target Limit for members of the public due to PDO activities shall not exceed 0.3
mSv/y above background.
The Target Limit for workers likely to be exposed to NORM is: 1 mSv/year.
The Target Limit for vessel/tank cleaning workers is: 2 mSv/year
The Maximum Limit for workers who may be exposed to Ionising Radiation during their
work activities is 10 mSv/year as defined in the MD249/97.

Occupationally Exposed Workers (Radiation Workers)

Exceptions are made for Contractors who are classified as Radiation Workers and are
submitted to medical examination as defined by a Medical officer. Employees who have the
potential to receive combined doses (internal/external) as a result of their work above 6 mSv/year
shall be classified as Radiological Workers.

For these workers, the dose must not exceed 10 mSv/year. Radiation Workers shall be defined
and record in the Health Risk Assessment for the Job Type. The Target level for Radiation Workers
for NORM is less than 2 mSv/year.

Individuals below the age of 18 years and pregnant women shall not be involved in work with
ionising radiation sources.

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In specific situations the RAC will decide if other exceptions are allowed.
Five Year
Annual Effective Dose
Affected Group Target Limit (mSv) Cumulative Dose
Limit (mSv)
Limit (mSv)
Incidentally exposed
1 1 5
workers
Tank/Vessel Cleaners
Sludge Farm 2 2 10
Operator
Radiation Workers
2 10 50
NORM

Members of Public 0.3 1 5

5.2 Derived limits

Exposure to Ionising Radiation is possible by external radiation and by internal radiation due to
inhalation and/or ingestion of radioactive substances. For practical purposes it is useful to define
job related exposure limits.
5.2.1 Dose rate limits
For worker protection when exposed to external radiation, where the radiation contour exceeds
2.5Sv/h then the area shall be designated as a radiologically Supervised Area. For example, this
might be the area immediately surrounding a vessel which is demarcated with tape and radiation
warning signs. In a Supervised Area exposure conditions are monitored to allow for reliable
prediction of the dose to individual workers. The dose-rate in a Supervised Area shall not exceed
7.5Sv/h.

Where the radiation contour exceeds 7.5 Sv/h, the area shall be designated as a Controlled Area
where specific protective measures and safety provisions are required.

The dose rate at the border of storage facilities inside the PDO premises, e.g. the designated area
for radioactive waste in Bahja shall not exceed 0.5 Sv/h.

Fences around PDO assets to which the public has access shall be set such that the maximum dose
rate at the outside of the fence shall not exceed 0.5 Sv/h above background.
5.2.2 Inhalation an/or Ingestion limits
To ensure that doses for inhalation/ingestion are ALARA, PDO has adopted a total protection
philosophy. Suitable PPE (e.g. filter masks) shall be used to prevent inhalation/ingestion of
radioactive substances arising from dust generating activities. Note: An inhalation risk only exists
where NORM contaminated scale, sludge, pigging wax or production water becomes airborne.
Where measurements with the Mini 900 with 44A probe indicate five (5) counts per second above
background, workers shall be required to wear the specified PPE.

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5.2.3 Monitoring of personnel
In order to monitor radiation exposure to individuals to ensure that the target limits are not
exceeded the dose of individuals shall be recorded and registered in a database. The action level
has been set at 1.0 Sv/h. Where the daily dose can exceed 8.0 Sv/day, this shall be recorded on
the NORM Radiological Survey with details of the individuals exposed. It is expected that the data
will indicate that actual exposure levels are well below set limits.

6. Measurements
Qualitative and quantitative field measurements of Ionising Radiation can be carried out at the
worksite, to determine the presence of ionising radiation sources and to check compliance with
dose limits.

Quantitative measurements of radioactive substances have to be carried out in a properly equipped

laboratory. These measurements are used to determine the composition and destiny of radioactive
waste or radioactive contaminated materials.

Procedures MSE.04 and MSE.06 explain the use of radiation instruments, interpretation of the
results and the actions to be taken.
6.1 Field measurements
Properly trained personnel using radiation monitors suitable for the type and energy of the Ionising
Radiation to be measured shall measure Ionising Radiation.

The RPA advises on equipment to be used. The selection of a monitor depends strongly on a number
of factors such as measurement principles, sensitivity, energy-dependence and robustness.

The following radiological protection instruments are currently in use at PDO.

Graetz5X survey meters for the measurement of external gamma dose-rate in (Sv/h).
The 900 Series Mini Monitor with Probe type 44A for the qualitative detection of gamma
radiation (in counts per second).
The 900 Series Mini Monitor with Probe type EP 15 for the detection of alpha/beta
contamination, (in counts per second).

All results shall be recorded on the NORM Radiological Report and entered into the database.
NORM contaminated equipment to be replaced or scrapped shall be monitored and each
component recorded using the NORM Report Form located in SP 1170 (Appendix I)
6.2 Laboratory measurements
Measurement of samples (activity concentration) needs sophisticated equipment, which is not
present in the field. If necessary, samples will be sent to a specialised institute, such as the
Sultan Qaboos University (SQU). MSE.07 Sampling for NORM provides guidance on the sampling
procedure. It includes the analysis request from, labelling and transport requirements to SQU.

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The results shall be emailed to the CRFPs , Production Chemistry and the requestor. All results
will be stored in the NORM Database.

7. Protective measures
Working with Ionising Radiation may lead to increased health risks. Therefore protective measures
have to be taken. Standard operating procedures will specify the required protective measures
(see NORM procedures MSE.03). Attention has to be given to:

instruction and information, e.g. in the toolbox meetings, sanitary regulations, monitoring by
radiation experts, supervision through controlled areas and restricted access, appropriate
use of PPE and auxiliaries.

8. NORM locations
NORM has been demonstrated at many places in or adjacent to PDO controlled areas. A detailed
overview is available from the NORM Database and each Asset shall have access to this information.
PDO shall have an annual program to identify NORM locations through surveys.

There is an ongoing programme for decontamination of affected areas. Criteria for remediation
are being specified.

9. Registration
In order to manage NORM in a controlled manner constant quantification of NORM contamination
is required through proper registration. Below, the required registers are summarised, while
detailed requirements for registration are specified in SP1170.
9.1 Register of radiological workers
It is PDOs policy to keep exposure to PDO employees below 1 mSv/year above background
wherever reasonably practicable. As a consequence there should be no one classified as
radiological worker and if so no dose registration is obligatory for PDO employees. Also no
medical surveillance and record keeping is necessary.

Contractors undertaking cleaning of NORM contaminated tanks/separators shall undergo personal

dosimetry through the use of TLD badges as they may exceed 2 mSv/year. Contractors shall be
responsible for developing and maintaining their own registers which must be readily accessible to
the worker and PDO auditors.
9.2 Personal radiation dose records
For re-assurance purposes dosimeters will be used on a selective basis for PDO employees and
results will be entered into the controlled database by the CRFP or an assistant. This database will
contain dose estimates calculated from work records where the daily dose exceeds 10 uSv/day.
These will be made available on request.

For exposure control NORM dose estimates shall be made using dose rate and exposure time
data.

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9.3 Registration of ionising radiation sources
Records must be kept of all ionising radiation sources on Company premises. Their exact location
should be known at any time (logbook). SP 1237 will specify the data to be kept. Contractors shall
keep their own registers and ensure that as a minimum the PDO requirements will be kept.
9.4 NORM
A registration system shall be used, that contains the relevant information to calculate risks and/or
dose estimates, plan protective measures and discuss options for waste disposal and decontamination
of equipment. The CRFP is responsible for this system and will specify registration forms to be
used by the RPS/RPT.

10. Storage, transport and disposal

Storage, packaging, transport and disposal are specified in MSE.08.

11. Emergency procedures

An emergency situation is defined as an unplanned, potentially hazardous exposure to Ionising
Radiation. An additional requirement is that corrective actions shall be taken within a reasonable
timeframe (one hour).

Due to the source strengths of isotopes within PDO the most likely emergency scenarios are:
an unplanned exposure to ionising radiation sources
trespassing the demarcated area
loss or any other unaccounted absence of ionising radiation sources
transport accident
Line management shall ensure emergency procedures are in place. Where the radiation work is
done by a contractor, the Contract Holder shall ensure the contractor has adequate emergency
procedures in place. These shall include the prescription of protective equipment
(e.g. shielding materials, remote handling equipment) and all corrective actions.
In addition to the urgent corrective actions, PDO management and the CRFP shall be informed
immediately to estimate exposure consequences and to plan additional actions.

12 NORM procedures
Whilst some references are contained within this document the total NORM management system
consists of:
NORM Specification SP 1170
NORM Management Guidelines
An overview of the NORM guidelines are enclosed in Appendix 2.

13. References
[1] Ionising Radiation Safety Guide, Shell Safety & Health Committee, 11/93
[2] PDO NORM Guidelines
[3] SP 1170 HSE Specifications NORM

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 Glossary of Abbreviations

Appendix 1
ALARA As Low As Reasonably Achievable
ICRP International Commission on Radiological Protection
NORM Naturally Occurring Radioactive Material
PPE Personal Protective Equipment
RAC Radiation Advisory Committee
RPA Radiation Protection Adviser
RPS Radiation Protection Supervisor
RPT Radiation Protection Technician
CRFP Corporate Radiation Focal Point

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 List of NORM Guidelines

Appendix 2
MSE
TITLE Remarks
No.
00 NORM Guidelines Master Document Version 1.0
01 Basis for derived limits and decision making
02 Routine and non routine jobs on NORM installations
03 Protection of personnel against NORM risks
04 Carrying out, recording and interpreting NORM surveys
05 Supervised and Controlled Areas
06 Registration of NORM contaminated materials, equipment & waste
07 Sampling for NORM
08 Packing, temporary storage, transport and final storage
09 Decontamination of personnel
10 NORM measuring programme
11 Radiological safety precautions for wireline jobs
12 Radiological safety precautions for dismantling equipment
13 Radiological safety precautions for NORM contaminated filters
14 Radiological safety precautions for NORM contaminated vessels and tanks
15 Radiological safety precautions for pigging operations
16 Radiological safety precautions for the workshop
17 Clean up of NORM contaminated areas
18 Control, issue and care of Radiation Protection Instrumentation
19 Dose rate assessment
20 Disposal of equipment To be issued
21 Decontamination of equipment
22 Control of contaminated equipment To be issued
23 NORM training
24 Radiological safety precautions for well re-entry
25 Radiological HSE Precautions for clean out of wells using Coil Tubing Units
Ionising Radiation Safety Guide Shell 1993

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