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Title: Transport of Low-Level NORM - A Case for Consistency and Practicality

Abstract

In 1996 the IAEA adopted a system for exemption of low-level radioactive material from transport regulations based on the principle that exemption values should be commensurate with the radiological risk posed by the material as estimated in terms of radiation dose (TS-R-1, 1996, Rev. 2005). For many naturally occurring radionuclides the dose-based, radionuclide-specific exemption concentrations tabulated in TS-R-1 were substantially lower than the previous radionuclide-independent definition of radioactive material (70 Bq g-1) due to the stringent dose criterion applied. It was recognized that this would bring huge quantities of previously unregulated natural materials handled in industry into the scope of the transport regulations. To minimize the economic impact of the dose-based values, a special provision in TS-R-1 provides for a 10-fold increase in exemption values for radionuclides in natural material provided the material is not intended to be processed for recovery of its radionuclides (Paragraph 107(e)). This provision reflects the IAEA concept that a dose criterion may be relaxed within cautious bounds to achieve a balance between practical issues and radiological concerns. For example, in a recent extension of the concepts underlying the IAEA Basic Safety Standards to bulk material (RS-G-1.7, 2004), the dose criterion for exposure to naturally occurringmore » radionuclides is, in effect, 100-fold greater than that for artificial radionuclides on the basis of practical considerations. However, the intended use aspect of Paragraph 107(e) is inconsistent with the basic principle underlying the Transport Regulations in that there is no dose basis for assigning different exemption values to identical materials on the basis of their anticipated use. In fact, under this provision the same material can move in and out of the scope of regulatory control as its anticipated use changes. The technical justification for safety requirements, or exemption from those requirements, for potentially hazardous material should be based on measurable properties of the material and not on intentions. To improve the practicality as well as the consistency of the Transport Regulations as applied to NORM, Paragraph 107(e) should be revised to apply to all natural materials, regardless of their intended use.« less

Authors:
 [1];  [2];  [1]
  1. ORNL
  2. NRC
Publication Date:
Research Org.:
Oak Ridge National Lab. (ORNL), Oak Ridge, TN (United States)
Sponsoring Org.:
Work for Others (WFO)
OSTI Identifier:
983535
DOE Contract Number:
DE-AC05-00OR22725
Resource Type:
Conference
Resource Relation:
Conference: PATRAM 2007, Miami, FL, USA, 20071021, 20071026
Country of Publication:
United States
Language:
English
Subject:
29 ENERGY PLANNING, POLICY AND ECONOMY; RADIOACTIVE MATERIALS; TRANSPORT; ACTIVITY LEVELS; NATURAL RADIOACTIVITY; ECONOMIC IMPACT; IAEA; RADIATION DOSES; SAFETY STANDARDS; TRANSPORT REGULATIONS; RECOMMENDATIONS

Citation Formats

Rawl, Richard R, Cook, John, and Leggett, Richard Wayne. Transport of Low-Level NORM - A Case for Consistency and Practicality. United States: N. p., 2007. Web.
Rawl, Richard R, Cook, John, & Leggett, Richard Wayne. Transport of Low-Level NORM - A Case for Consistency and Practicality. United States.
Rawl, Richard R, Cook, John, and Leggett, Richard Wayne. Mon . "Transport of Low-Level NORM - A Case for Consistency and Practicality". United States. doi:.
@article{osti_983535,
title = {Transport of Low-Level NORM - A Case for Consistency and Practicality},
author = {Rawl, Richard R and Cook, John and Leggett, Richard Wayne},
abstractNote = {In 1996 the IAEA adopted a system for exemption of low-level radioactive material from transport regulations based on the principle that exemption values should be commensurate with the radiological risk posed by the material as estimated in terms of radiation dose (TS-R-1, 1996, Rev. 2005). For many naturally occurring radionuclides the dose-based, radionuclide-specific exemption concentrations tabulated in TS-R-1 were substantially lower than the previous radionuclide-independent definition of radioactive material (70 Bq g-1) due to the stringent dose criterion applied. It was recognized that this would bring huge quantities of previously unregulated natural materials handled in industry into the scope of the transport regulations. To minimize the economic impact of the dose-based values, a special provision in TS-R-1 provides for a 10-fold increase in exemption values for radionuclides in natural material provided the material is not intended to be processed for recovery of its radionuclides (Paragraph 107(e)). This provision reflects the IAEA concept that a dose criterion may be relaxed within cautious bounds to achieve a balance between practical issues and radiological concerns. For example, in a recent extension of the concepts underlying the IAEA Basic Safety Standards to bulk material (RS-G-1.7, 2004), the dose criterion for exposure to naturally occurring radionuclides is, in effect, 100-fold greater than that for artificial radionuclides on the basis of practical considerations. However, the intended use aspect of Paragraph 107(e) is inconsistent with the basic principle underlying the Transport Regulations in that there is no dose basis for assigning different exemption values to identical materials on the basis of their anticipated use. In fact, under this provision the same material can move in and out of the scope of regulatory control as its anticipated use changes. The technical justification for safety requirements, or exemption from those requirements, for potentially hazardous material should be based on measurable properties of the material and not on intentions. To improve the practicality as well as the consistency of the Transport Regulations as applied to NORM, Paragraph 107(e) should be revised to apply to all natural materials, regardless of their intended use.},
doi = {},
journal = {},
number = ,
volume = ,
place = {United States},
year = {Mon Jan 01 00:00:00 EST 2007},
month = {Mon Jan 01 00:00:00 EST 2007}
}

Conference:
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  • This paper presents a case history of ARCO Oil and Gas Company`s (AOGC{sub 1}) Naturally Occurring Radioactive Material (NORM) injection project that was conducted offshore in the Gulf of Mexico. The unique aspect of this project is that it was performed entirely offshore, using drill cuttings injection equipment. This project involved grinding and injecting approximately 1300 bbls of various NORM. Discussed in the paper is the historical regulatory considerations, reservoir selection and permitting process, pre-frac design process, the washing, grinding and injection process, and on-site data frac analysis and fracture post-mortem.
  • NORM waste consists of naturally occurring radioactive material associated with oil and gas operations as scale deposited in tubulars, surface piping, pumps, and other producing and processing equipment. NORM also occurs as sludge and produced sands at wellheads, transport vessels and tank bottoms. For disposal, NORM scale and sludge are separated from the tubulars and tank bottoms and ground to less than 100 microns and mixed into a slurry at the surface facility for disposal into a deep well injection interval below the Underground Sources of Drinking Water zone. This paper addresses two primary considerations: (1) subsurface geologic investigations whichmore » identify specific geologic horizons that have sufficient porosity and permeability to accept NORM slurries containing high total suspended solids concentrations, and (2) surface facility requirements. Generic and specific information, criteria, and examples are included in the paper to allow the application of the geologic principles to other areas or regions.« less
  • The Ashtabula River in northern Ohio contains a large amount of sediment containing quantities of NORM and TENORM from previous industrial activities at nearby mineral processing plants. Due to PCB contamination, these sediments were to be dredged and isolated in a landfill to be constructed by the responsible parties. Unfortunately, the State of Ohio has determined that these wastes may not be disposed of in this manner, and this determination has resulted in delaying the remediation project. Computer models performed using the RESRAD computer code indicate that isolating these wastes in this manner will reduce dose to the nearby populationmore » because the NORM/TENORM will be safely buried beneath a compacted clay cover and isolated from all sources of exposure. In fact, radiation doses (including radon emanation) from these wastes in a properly maintained landfill are significantly lower than in the present condition, and the reduction is even more marked for NORM/TENORM in tailings piles. This suggests that, in many cases, disposal of NORM/TENORM wastes in on-site landfills may be a cost-effective and dose-conscious method of disposal, if regulatory issues can be resolved.« less
  • The Federal Facility Compliance Act of 1992 requires the US Department of Energy (DOE) to prepare an inventory report of its mixed waste and treatment capacities and technologies. Grouping waste streams according to technological requirements is the logical means of matching waste streams to treatment technologies, and streamlines the effort of identifying technology development needs. To provide consistency, DOE has developed a standard methodology for categorizing waste into treatability groups based on three characteristic parameters: radiological, bulk physical/chemical form, and regulated contaminant. Based on category and component definitions in the methodology, descriptive codes or strings of codes are assigned undermore » each parameter, resulting in a waste characterization amenable to a computerized format for query and sort functions. By using only the applicable parameters, this methodology can be applied to all waste types generated within the DOE complex: radioactive, hazardous, mixed, and sanitary/municipal. Implementation of this methodology will assist the individual sites and DOE Headquarters in analyzing waste management technology and facility needs.« less