DaQing Drilling Company, Halfaya Iraq

DaQing Drilling Company

Halfaya Project, Iraq

Document Title NORM (Naturally Occurring Radioactive Materials)

Procedure

Document ID HSE/ZT/5.8-7

Document Type Procedure

Issue Date 20-August-2023

Revision 1.2

Copyright Note: The Document is the property of DaQing Drilling Company and no part of
this document may be reproduced, distributed, or transmitted in any form or by any means,
including photocopying, recording, or other electronic or mechanical methods, without the
prior written permission of the DaQing Base, HSE Department, Halfaya Project.

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 DaQing Drilling Company, Halfaya Iraq

Document Authorization

Authorized for Issue

Description Name Signature

Prepared By: Zaman Rizwan

Reviewed By: Shi Honggang

Approved By: Project Leader

Zaman Rizwan
Document Custodian
[Link]

Current Version 1.2

Issue Date 20-August-2023

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Revision History
The following is a brief summary of the most recent revisions to this document. Details of all
revisions prior to these are held on file by the issuing department.

Version No. Date Author Scope/Remarks

1.0 01-Feb-2018 Zaman Rizwan Initial
1.1 13-Feb-2022 Muhammad Ejaz Management review & format update
1.2 20-August-2023 Zaman Rizwan Management review & logo update

Relevant Procedures:
Environment Management Procedure

PTW (Permit to Work) Procedure

Management of Change Procedure

Relevant Records:
Waste Transfer Note Record

Radiation survey record

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TABLE OF CONTENTS
1. INTRODCUTION ......................................................................................................................... 5
1.1 Purpose ............................................................................................................................... 5
1.2 Scope ................................................................................................................................... 5
1.3 Definition ............................................................................................................................. 6
2. Responsibilities .......................................................................................................................... 7
2.1 Rig Manager......................................................................................................................... 7
2.2 Area Custodian .................................................................................................................... 7
2.3 HSE Supervisor ..................................................................................................................... 7
2.4 Performing Authority ........................................................................................................... 7
2.5 Work Party ........................................................................................................................... 8
3. NORM (Naturally Occurring Radioactive Material) ..................................................................... 9
3.1 NORM Exposure and Hazard ................................................................................................ 9
3.2 NORM Contaminated waste (Greater than 3 CPS above background levels) ....................... 10
3.3 NORM-Local Handling Rules (>3 CPS above background levels) ......................................... 15
3.4 NORM storage (>3 CPS above background levels)............................................................... 17
3.5 Transportation of NORM .................................................................................................... 18
3.6 Disposal of NORM: ............................................................................................................. 19
3.7 Emergency Action Plan....................................................................................................... 19
4. TRAINING AND AWARENESS .................................................................................................... 20
5. COMPLIANCE AND AUDITING................................................................................................... 20
6. CONTINUOUSLY EVALUATE AND IMPROVEMENT ..................................................................... 20

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1. INTRODCUTION
Naturally Occurring Radioactive Materials, otherwise known as NORM, are widely distributed
throughout the earth’s crust and within the reservoirs where oil and gas are produced. These
elements include the primordial radionuclide uranium and thorium and their progeny, including
radium, radon, lead and polonium isotopes. Together with other naturally occurring radioactive
isotopes, such as potassium-40, these radionuclide give rise to natural background radiation. During
the exploration and production of oil and gas, NORM can be transported from the subsurface to
equipment, installations and byproducts.

Contaminated scale has been detected on sub-surface equipment e.g. tubular, pumps, vessels
(degasser) , Mud tanks and surface equipment e.g. Xmas trees, valves and flow lines several times in
Oil & Gas industry. NORM contaminated sludge have also accumulated in tanks, vessels and pigging
receivers and evaporation ponds.

NORM not only present a potential health risk to DQDC and contractor staff maintaining and
servicing production equipment or handling waste streams as these naturally occurring elements
emit gamma photons and alpha and beta particles which are potentially harmful to health if inhaled
or ingested, but may also result in an environmental legacy. NORM wastes contain long-lived
radionuclide (radium-226 with a half life of 1600 years).

This has important implications for the choice of disposal options and long time periods for which
control might be necessary.

1.1 Purpose
This procedure describes DQDC minimum requirements for managing NORM, which may be
hazardous to health or the environment as a result of DQDC oil and gas exploration. NORM will be
handled in DQDC on the basis of the Precautionary Principle.
This involves:
 Ensuring that no DQDC employee, contractors or members of the public are exposed to
NORM above the accepted International, local and DQDC standards.
 Avoiding uncontrolled releases of radioactive contaminated substances and minimizing the
effects of past deposits.
 Assuming NORM is present (where the potential exists) until proven otherwise.
 Incorporating NORM monitoring into the Permit to Work System.
 Constantly updating our knowledge of NORM based on international best practices.

1.2 Scope
The scope of this procedure is to ensure that work with naturally occurring radioactive material is
carried out safely and that specific measures will be taken to comply with statutory controls
affecting:-Work involving the processing, handling, use, storage, transport, or disposal of
naturally occurring radioactive material.
This procedure is applicable to all DQDC personnel involved with naturally occurring radioactive
material at any Halfaya facility.

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1.3 Definition

Alpha particle decay: A high-energy positively charged particle ejected from the nucleus of an
unstable (radioactive) atom, consisting of two protons and two neutrons. E.g. radium226 (226 Ra) is
an alpha emitter decaying to radon-222 (222Rn)

NORM: Naturally Occurring Radioactive Materials are materials produced by members of the
decay series of naturally occurring uranium–238 (238U) and thorium-232 (232Th) and other radioactive
nuclei. In oil- and gas operations, only progeny from the uranium and thorium decay series are
encountered, together with potassium-40 (40K).

NORM Contaminated Area: An area (e.g. around leaking installations pumps vessels, flow
lines, well heads) will be classified as a “NORM contaminated Area” when the readings with a
radiation dose rate monitor exceeds the natural background by at least 3.0 μSv/hr.

NORM Contaminated Equipment: Any equipment of which the dose rate exceeds 3.0 μSv/hr.

NORM Contaminated Sludge: Any sludge or debris removed from tanks, vessels or pigging activities
of which the dose rate exceeds 3.0 μSv/hr or greater than 1 Bq/g for 226 Ra after laboratory analysis
by gamma spectrometric analysis.

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2. Responsibilities
2.1 Rig Manager
Rig manager has overall responsibility for the health and safety of personnel and environment
protection at each site. Rig Manager is also responsible for ensuring that all precautions and
controls are implemented at his site when any work involving naturally occurring radioactive
material is being carried out.

2.2 Area Custodian

The Area Custodian is responsible for the area where naturally occurring radioactive material is
located.

The Area custodian will ensure that all barriers are erected and measures are implemented to
reduce the risks 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) and that it is in a serviceable condition.

2.3 HSE Supervisor

The HSE supervisor shall assist the Area custodian and Rig Manager in ensuring that all
precautions stated on the Permit are implemented.

The HSE Supervisor is responsible for:-

 Monitoring of the work area;
 Ensuring that safe working practices are being enforced at all times.

2.4 Performing Authority

The Performing Authority 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 impacted by 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
conditions applicable to the work;
 Ensuring everyone concerned understands the task, the hazards and the precautions
especially where the work party is multi-lingual;
 Ensuring the Permit, JHA and any other associated documentation is displayed at the work
site, wherever practicable.

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2.5 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
naturally occurring radioactive material;
 Alerting the Performing Authority on identifying where the conditions specified in the Permit
cannot be complied with.

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3. NORM (Naturally Occurring Radioactive Material)

NORM (Naturally occurring radioactive material) is a natural component of our environment
which is found in geological formations (Figure 1). It is usually brought to the surface in oil
and gas exploration and production process. As the liquid approaches the surface, temperature
and pressure change causes radioactive elements to precipitate out of the liquid phase and form
solids. Resulting scale and sludge may collect in piping and vessels in crude or water separation
systems. Radium is usually found in this type of naturally occurring radioactive material
contamination.

Figure 1: The origin of Natural Occurring Radioactive Material in Drilling Process

3.1 NORM Exposure and Hazard

Radium 226 and Radium 228 are the principal radioisotopes associated with oil and gas
fluids. These elements 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 two neutrons (essentially a helium nucleus without the electrons of a helium atom) with a
charge of plus 2, and an 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 2). Human exposure may occur when contaminated dusts and sludge are inhaled or ingested
(internal exposure) or when gamma radiation from surrounding equipment strikes the body
(external exposure). When scale containing alpha emitters dries and becomes airborne as dust,
alpha emitting particles can be inhaled deeply into the lungs of people in the area. Alpha radiation
released in lung tissue can cause serious damage. Gamma and beta radiation also released by NORM
scale are relatively weak and present a much lower radiation hazard.

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Figure 2: Exposure to NORM from internal and external sources

Potential long term Health effects

Unprotected overexposure to radium and radium daughter contaminated dusts has been associated
with an increased risk of lung cancer and leukemia. Most naturally occurring radioactive material
taken into the body 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
recognized exposure standards and unnecessary exposure to radiation should be minimized.

3.2 NORM Contaminated waste (Greater than 3 CPS above background

levels)
If any naturally occurring radioactive material is suspected, contact the Halfaya Environmental
team to obtain additional information and allow for the further evaluation of the material to
determine if it is NORM and, if necessary, how to handle and dispose of the waste.

Naturally occurring radioactive contaminated materials exceeding 70 Becquerel’s per gram (70
Bq/gm) are subject to:-

 UN recommendations on the transport of dangerous goods requirement.

 International Maritime Dangerous Goods Code.
 International Air Transport Association Dangerous Goods Regulations.

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Naturally occurring radioactive material contaminated wastes may include filters from contaminated
process streams, 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 entry restricted. The storage area requires periodic radiation surveys to ensure gamma levels
are not increasing above hazardous levels and/or site contamination is not occurring from leaking
containers.

Wastes should be barreled, preferably plastic to prevent corrosion, labeled and stored.

Naturally occurring radioactive material contaminated wellhead equipment require special

handling procedures.

Install closed end thread protectors on each end of pipe and tubular assembly pieces.

The pipe and equipment must remain with ends secured until they are transferred to a protecting
cleaning area. The pipe and equipment must be labeled according to its level of activity when
transporting.

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NORM
Survey

Identify NORM
NORM Yes contaminated
Declare Equipment/Waste

NO
Workers Protection &
Normal
contamination control
Operation
measures

NORM
Norm
contaminated
contaminated
Equipment
Waste

NORM free Decontaminate

Equipment NORM Equipment

Norm contaminated NORM Waste

Waste Interim Storage

NORM waste
permanent
disposal

Figure 3: Schematic of surveying for naturally occurring radioactive materials

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Definitions Radiation Measurement Actions to Take

NORM contamination >3 cps above Background PPE requirements are in
to implement effect as noted in Section
personnel protection 3.3.
and/or limit employee
exposure time. >7.5 uSV/hr Establish barricaded area and limit
exposure time per Figure 4 and Table
1.
Definition of >3 CPS above Label with NORM contamination tag.
environmental NORM background(alpha/beta or Place in NORM disposal container.
contamination gamma) Move disposal container to interim
NORM storage until further laboratory
analysis can be conducted.

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Is there the potential

No
for exposure to End
radiation?

Yes

Carry out initial radiation check

on breaking of containment
and before any work begins.

Reading is less than No ‘Controlled Area’

Consult with PetroChina HSE
7.5 µSv/hr?
Department

Yes

Yes
Proceed with work, Reading is less than
complying with Permit 3.0 µSv/hr?

No

Is total estimated
End Unsure Consult with PetroChina
exposure greater than 1
HSE Department
mSv/year.

(1 millisievert/year)

Yes

Comply with the

management of NORM

Figure 4: Radioactive material flow chart

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Table 1 dose readings correspondence to allowed minimum exposure time per day per worker.
Dose rates will fall off rapidly with distance (using barriers and signs) and effective shielding (for
example, high mass materials and graphite).

Dose readings (µSv/hour) Maximum allowed exposure time (min/day)

3.5 130
4 115
5 90
6 75
7 60
Table 1: Dose Reading’s

Note: For non-classified workers (annual exposure < 1mSv)

3.3 NORM-Local Handling Rules (>3 CPS above background levels)

The following are the operational steps which are to be taken for the safe management of naturally
occurring radioactive material, which includes background measuring naturally occurring
radioactive material levels.

Personnel and equipment contamination checks before, during and after work involving naturally
occurring radioactive material is carried out. Measurements of Alpha Beta or Gamma radiation that
is greater than 3 counts-per-second above background levels requires implementation of local
handling rules.

 PetroChina HSE specs is to be referenced in conjunction with this procedure.

 Any work which requires or may involve personnel coming into contact with naturally
occurring radioactive material is to be planned and include a JHA before the work
commences;
 Agree with the site where the work is to be carried out that there will be no simultaneous
operations that may affect or impact the safe working distance/controlled area for the
naturally occurring radioactive material work;
 Prior to the work commencing the toolbox talk checklist and PCH Radiation certificate is
to be completed with the team assigned to complete the work. Only approved workers
are permitted to work with naturally occurring radioactive material. This will include the
barrier equipment and the following PPE:-
 ‘Tyvek’ style coveralls
 Neoprene, Polyvinyl Chloride (PVC) or nitrite rubber gloves
 Half-face respirators with high-efficiency particulate air cartridges.

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 Quarter-face high efficiency particulate air disposable respirators.

 During the work no personnel are permitted to eat or drink within the work area. Drinking
and eating can only happen once the worker has been checked for contamination and the
personal protective equipment removed, bagged and sealed for disposal. Hygiene is very
important with the washing of hands and face being mandatory.
 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 unauthorized personnel from entering the
area for the entire duration of the work.
 Openings of equipment or pipes that have internal naturally occurring radioactive
material contamination 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 fits correctly and is used. The workers are checked for contamination
during/after working with the naturally 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 labeled as “naturally occurring radioactive material contaminated materials”
and removed to a designated storage area. The area should be labeled as
“containing radioactive materials” and restricted from the general public.
 All contaminated waste generated during maintenance should be drummed or put
into containers and marked or labeled. Representative samples should be collected from
the waste and analyzed for radioactivity.
 Once the work has been completed and the area is confirmed as being cleared of naturally
occurring radioactive material, the naturally occurring radioactive material waste and
equipment is bagged and sealed along with contaminated personal protective equipment.
The waste is to be removed from the site by the approved team.
 Disposal has to be confirmed by PetroChina Environment team.
 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 MUST STOP UNTIL
THEY ARE IMPLEMENTED.

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3.4 NORM storage (>3 CPS above background levels)

Where naturally occurring radioactive material waste is required to be stored at a Rig site, it shall be
kept 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
storage period;
 Shall be made of, or lined with, materials that will not react with or be incompatible with the
waste so that 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 to add 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 of
ground/surface water and the creation of contaminated land from any potential leaks/spills as
a result of incidents during storage period Areas where containers of naturally occurring radioactive
material waste are stored should be inspected on a regular basis. Containers should be inspected
for signs of leakage, overall deterioration and proper labeling. Records of these inspections
should be documented and properly maintained.

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 6)
 Yellow or magenta rope, tape, chains or other barriers (Figure 5)
 Yellow tags and labels with the standard radiation symbol in magenta or black.

Figure 5: Radiation Warning Tape Figure 6: Radiation Warning Sign

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3.5 Transportation of NORM

Adequate precautions are needed for the safe and traceable transportation of NORM contaminated
equipment and NORM wastes including scales, sludge’s and contaminated personal protection
equipment (PPE) such as gloves and coveralls.
This is to ensure that no NORM can contaminate either the transportation vehicle or route.
To make transportation safe and secure:
 Only use PCH authorized transportation company.
 Follow up DQDC and PCH traffic safety policy and procedure.
 Follow up Journey management plan.
 Control waster transfer process with WTN (Waste Transfer Note).
 NORM contaminated equipment/items should first be wrapped/bagged to prevent the
escape of NORM, labeled, then secured in a transport container.
 NORM contaminated sand/scale/sludge must be packaged for transport in suitable drums or
skips, with the end storage/disposal route often dictating which type are used. The specific
activities present in the waste, along with the presence of any other hazards, will also
influence the choice of container.
The aim shall to ensure that there is no escape of material during transport, therefore checks
should be made that seals are intact and lids fit correctly as shown in (Figure 7).

Figure 7: NORM prepared for transportation

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3.6 Disposal of NORM:

Disposal site has to be confirmed by MOC (Maysan Oil Company), MOE (Ministry of Environment)
and PetroChina Halfaya Project.
Where naturally occurring radioactive material waste is disposed of, records shall be
maintained of the disposal activities. They should include but are not limited to:-
Waste material description; for example, scale, sludge and scrapings
Volume of waste material
Transporter Data
Naturally occurring radioactive material level (activity per unit weight) of waste material
Methods of disposal
Disposal location
Organization/facility where the naturally occurring radioactive material waste was generated
Any other relevant information

3.7 Emergency Action Plan

 Keep unnecessary people at least 150 feet upwind of spill greater distances may be
necessary for people downwind, or if advised by Radiation Authority.
 Isolate the area and deny entry.
 Response actions may be performed prior to any radiation measurements.
 Positive pressure self-contained breathing apparatus (SCBA) and structural fire fighter's
protective clothing will provide limited protection.
 Notify PCH HSE department of accident conditions.
 Detain uninjured persons, isolate equipment with suspected contamination, and delay
cleanup until instruction form PCH HSE department.
FIRE
 Do not move damaged containers: move undamaged containers out of the fire zone.
 Small Fires: Dry chemical, CO2, water spray, or regular foam.
 Large Fires: Water spray, for or regular foam.

SPILL OR LEAK
 Do not touch damaged containers or spilled material.
 Dike far ahead of spill to collect runoff water.
 Cover powder spill with plastic sheet or tarp to minimize spreading.

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4. TRAINING AND AWARENESS

Training and awareness are major components of a NORM management system. Workers need to be
made aware of:

 The hazards associated with NORM

 Procedures to identify NORM (and the challenges herein)
 Controls that are required for their personal protection
 Methods for preventing environmental contamination
 Local documentation requirements and how to escalate actions over uncontrolled risks or
non-conformant operations.

Training should focus on operational personnel who are potentially exposed to NORM and directly
involved in maintenance operations. However, basic awareness should also be given to all the
personnel involved in the facility, even though they are not involved directly or have low immediate
risk of being involved.
Basic training should be refreshed at regular intervals and whenever a significant change is
encountered – such as the introduction of new equipment. Key personnel should be identified and
provided with training that will permit them to ensure that the work they do pays due regard to the
NORM hazards and prevent spreading. Training should be tailored to the specific potential hazard
associated with NORM to which the personnel is exposed to.

5. COMPLIANCE AND AUDITING

It is essential that complete records are maintained of all naturally occurring radioactive materials
found and disposed of at Halfaya approved facility. The HSE Department will maintain these records.
The following information will be held:-
 Naturally occurring radioactive material records.
 Waste Transfer Notes Record.
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.

6. CONTINUOUSLY EVALUATE AND IMPROVEMENT

Like any part of HSE Procedure, NORM procedure must continuously evolve to meet our changing
needs. The company will review the NORM procedure effectiveness at least once per three years.

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