Oman PDO NORM Regulation and Specifications Ahmed AlSabahi

Oman & PDO NORM Regulation and Specifications Ahmed Al-Sabahi Corporate Environmental Advisor

Oman & PDO NORM Regulation and Specifications in PDO • Royal Decree No. 114/2001 Issuing the Law on Conservation of the Environment and Prevention of Pollution issued by MRMEWR. • Ministerial Decision No. 249/97 issuing the regulations for the control and Management of Radioactive Materials – issued by MRMEWR. • SP 1170 PDO Specification for naturally Occurring Radioactive Materials (N. O. R. M. )

ROYAL DECREE No. 114/2001 THE LAW ON CONSERVATION OF THE ENVIRONMENT AND PREVENTION OF POLLUTION Ministry of Regional Municipalities, Environment & Water resources 14 November 2001

ROYAL DECREE No. 114/2001 ISSUING THE LAW ON CONSERVATION OF THE ENVIRONMENT AND PREVENTION OF POLLUTION • Chapter I • Article 1 (Definitions) • Nuclear waste: Waste having radiation activity more than 100 Becquerels /gm. which poses risk to human life and health or the environment whether by itself or as a result of its contact with other waste.

• Article (18) • The owner of any nuclear establishment or any establishment dealing with radioactive materials whether through transportation, storage or usage, shall obtain the prior consent of the Ministry and shall submit for the Ministry’s approval, a contingency plan to encounter risks of radioactive pollution. • The Ministry shall monitor nuclear radiation in coordination with regional and international monitoring centres as per the procedures to be specified by the Minister.

• Article (42) • Without prejudice to any severer penalty provided for in any other law, whoever disposes of nuclear waste in Oman environment shall be punished with imprisonment for life and with fine not less than RO 100, 000 and not exceeding RO 1, 000 or with any of the two penalties. The violator undertakes to remove causes of the violation and reinstate the environmental status at his own expense in addition to payment of the compensation specified in this regard.

MINISTERIAL DECISION No. 249/97 Regulations for the Control and Management of Radioactive Materials Ministry of Regional Municipalities, Environment & Water Resources. 6 JULY 1997

MINISTERIAL DECISION No. 249/97 Regulations for the Control and Management of Radioactive Materials • • The Regulation not only covers NORM, but also other radioactive materials and issues. 27 Articles. Article (1) – Definition Radioactive materials: Any material with an activity concentration > 100 Bq/g. (Assume total activity)

Cont. Definition • Radioactive waste: Unwanted radioactive material that contains concentrations greater than the levels of 100 Bq/g

• Article (2) : Any organization intending to import, transport, store or use radioactive materials, or equipment containing radioactive materials, must apply to the Ministry for a permit by completing the prescribed application form and enclosing all supporting documents and payment of established fees from which government bodies are exempted. • The permit shall be valid for one renewable year.

• Article (17): Vehicles used for the transport of radioactive materials within the Sultanate of Oman must obtain approval of the Directorate General of Civil Defense (Royal Oman Police) before being used • Article (22): Permanent storage of radioactive materials shall be permitted only at locations approved by the Ministry. The organization using these locations should have written procedures of operation, security facilities, dose rate limitations, notices and labels. A prior approval from the Ministry must be obtained for any proposed temporary locations for storing radioactive material for a period not exceeding 24 hours.

• Article (23): • The storage locations must fulfill the following : ØShould be away from populated areas. ØAll radioactive materials shall be adequately shielded, labeled and kept in locked and secure places to protect them from theft, damage or use by unauthorized persons. ØSpecial procedures shall be established for control of the storage facilities keys. ØClearly label "Radioactive Materials" both in Arabic and English on each store containing radioactive materials as per instructions of the Ministry. ØThe dose rate outside the storage facility shall not exceed 2. 5 u. Sv/h.

• Article (26): Importation of radioactive waste for final disposal in the Sultanate of Oman is absolutely prohibited.

PDO Naturally Occurring Radioactive Materials (N. O. R. M. ) Specification SP 1170

• Purpose This specification describes PDO's minimum requirements for managing Naturally Occurring Radioactive Materials (NORM), which have the potential to be a hazard to human health or to harm the environment, as a result of PDO’s activities, products or services. • Scope PDO has identified NORM as an issue to be managed in its operations. PDO have already acquired experience in NORM monitoring, handling, transport and storage. PDO is yet to undertake any substantial work on NORM treatment and disposal.

• This specification covers PDO’s practices for: Monitoring, handling, transport and storage of NORM contaminated materials and Working in NORM suspect, supervised and restricted areas. • It does not cover issues of treatment and disposal of NORM • Definitions: – Radioactive Material: Is a material classified as radioactive, if the total activity is greater than 100 Bq/g.

• Contd, Definitions Ø NORM: Naturally Occurring Radioactive Materials are materials produced by members of the decay series of naturally occurring Uranium– 238 and Thorium-232 or other similar radioactive nuclei. Ø Norm Contaminated Area: Is an area where the NORM count in the area, as measured by a NORM contamination meter, exceeds the background levels by at least 5 counts per second on the Mini Instruments series 900 with a 44 A probe. . Ø NORM Contaminated Materials: NORM contaminated materials are produced when NORM is attached to the surface of materials either directly as elemental deposits or indirectly incorporated in salt deposits.

• Responsibilities Ø Radiation Advisory Committee (RAC). Ø Corporate Radiation Focal Point (CRFP). Ø Asset Managers Ø Corporate Functional Discipline Heads Ø Area Coordinators/Project Managers/Well Site Supervisors Ø Interior Radiation Focal Point Ø Radiation Protection Advisor Ø Corporate Environmental Advisors

• Performance Monitoring An integrated NORM monitoring program shall be developed, implemented and maintained to demonstrate compliance with this Specification and any additional requirements specified in an Environmental Permit. The monitoring program should supply the necessary data to prepare the required reports for NORM

• Reporting Ø A report shall be prepared by the IRFP and sent to the CRFP in accordance with the RAC meeting schedule. The report will include: Ø Number of areas surveyed. Ø Locations of NORM contaminated areas. Ø Locations of identified NORM areas. Ø Inventory of NORM contaminated equipment and materials in the Storage Site Ø Results of NORM analyses

• Monitoring ØAll materials operations, where there is a reason to believe NORM contamination exists, must be monitored using a contamination monitor. (The recommended monitor is currently the Mini Instruments series 900 with a 44 A-scintillation probe. ). ØAll operations involving exposure to production fluids have the potential for NORM contamination. In particular, consider oil sludges, pigging wastes, tubulars and water/well accessories from reservoir locations where NORM has been detected in the past should be considered.

• Handling of Radioactive Material ØAll NORM contaminated material must be handled in a manner that ensures no ingestion or inhalation of contaminated material can take place. ØThe general principles for all operations are: ØThe number of personnel involved in the operation must be kept to a minimum. ØAccess to NORM areas must be controlled. ØAll personnel involved with the work must wear personal protective equipment, as given in Appendix C

ØThe following activities are prohibited in the area: eating, drinking, smoking, licking glued labels, and the use of cosmetics, personal handkerchiefs and mouth pipettes. ØAll personnel must decontaminate and wash with water before they leave the site of operation. ØAll personnel working with NORM must be monitored with a contamination meter before leaving the area (after washing). ØAll NORM contaminated materials or silts must be wrapped, sealed or drummed before they leave the area of operation

• Transport of Radioactive Material Ø Contaminated tubulars will be end-capped with each tubular labelled as NORM contaminated. Ø Any tubulars contaminated on the outside or with any with holes in them will be wrapped in polyethene and transported in a completion skip. Ø The maximum dose rate at any point on the outer surface of the any vehicle loaded with NORM shall be not exceed 2 m. Sv/hr. Ø The maximum dose rate at one meter distance from the outer surface of any vehicle carrying radioactive material shall be not exceed 0. 1 m. Sv/hr.

Ø The maximum dose rate at the driver's seat shall be not exceed 2. 5 Sv/hr. Ø After loading, the container will not be opened until it reaches the storage site at Zauliah. Ø All transport of NORM shall be tracked using the NORM Record of Movement Form (Appendix B). Ø The vehicle transporting NORM shall have minimum stop-overs on route to its destination. Ø Each driver of vehicles carrying NORM shall not drive for more than 4 hours without a break and the total working hours shall not exceed 10 hours per day. Ø After unloading, the container is to be checked for contamination before being used again. Ø Normal transport vehicles can be used. •

• Storage of Radioactive Material • All NORM contaminated items or materials must be taken to the PDO designated storage site in Zauliyah as soon as reasonably practicable. The NORM storage area must comply with the following: • The NORM storage areas must be protected with proper fencing and security so that uncontrolled entry is not possible. • There must be proper signage (pictorial and written in English and Arabic) around the fence so that the hazards are understood by everybody.

• A contour of dose rates for the site shall be available through the supervisor. • People who are given access to the site are briefed on the location of hazards. • The key for access to the site must only be issued to authorised personnel and must be signed out and back into the custodian’s control. • The dose rate outside at the fence of the storage facility shall not exceed 2. 5 Sv/hr.

• Disposal of Radioactive Material Ø Materials which cannot be de-contaminated, in addition to the by-products of the decontamination activity (after removal of NORM scales and silts), can only be disposed of into the designated disposal facility.