Management of Naturally Occurring Radioactive Materials

Management of Naturally Occurring

Radioactive Materials

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Management of Naturally Occurring Radioactive Materials

Rumaila Operation Organisation

Management of Naturally
Occurring Radioactive
Materials
ROO-ALL-HS-PRO-0109

This is a Rumaila Operating Organization controlled document. Any change to this document shall be reviewed
and approved by the appropriate site prior to use and issue.

Any documents not approved in this manner will be uncontrolled.

*Paper copies are uncontrolled. This copy valid is only at the time of printing. The controlled version of this
document can be found in ROO HSE SharePoint.

Distribution
Position Electronic Copy Hard Copy
All stakeholders X

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Management of Naturally Occurring Radioactive Materials
Revision history

Revision Brief description of Rumaila

Date Prepared Reviewed Approved
number change approved
001 16/05/12 For client review RC RS JL
and adjustment

002 12/06/12 Client changes RS

003 17/07/12 Client changes RS

004 27/06/14 Periodic review

005 14/07/15 Addition of SOPs RJ

and periodic review

006 26/02/16 Update of SOP03 RJ

007 29/06/16 Addition of SOP06 RJ

008 16/10/16 Change of e-mail WEP IF RJ LJ

contact details

009 28/09/17 Update to SOPs RJ JM RJ LJ

and addition of
SOP13
010 07/02/18 Minor update to RJ RG RJ RE
SOPs

011 24/07/20 Periodic review

012 28/04/21 Addition of NORM Aladien.Altaay

check forms

013 30/03/22 Updating to SOPs Aladien.Altaay

014 27/06/2021 Reformatting Lina I. ALSabbagh

Digitally signed by Digitally signed by

Rufat Digitally signed
015 27/04/2022 Client change Aladien.Altaay Ihsan Failh Ihsan Failh Hendi
Ihsan Falih Ihsan Failh Ihsan Failh Hendi by Rufat
Garada Garadaghi
Hendi Date: 2022.04.27
Hendi Date: 2022.04.28 Date: 2022.04.27
11:59:57 +03'00'
08:17:59 +03'00' ghi 13:17:11 +03'00'

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Management of Naturally Occurring Radioactive Materials
Table of Contents
1. PURPOSE................................................................................................................. 6
2. SCOPE ..................................................................................................................... 7
3. LEGAL AND REGULATORY REQUIREMENTS .............................................................. 8
Iraqi Legislation ....................................................................................................................................... 8
3.1.1 Dose Limits ...................................................................................................................................... 8
3.1.2 Classification of Radioactive Materials ........................................................................................... 8
Recommendations of the RPA ................................................................................................................ 8
3.2.1 The IAEA Basic Safety Standards ..................................................................................................... 8
Transport Regulations ............................................................................................................................. 9

4. RADIATION MANAGEMENT OVERVIEW ................................................................. 10

Roles and Responsibilities..................................................................................................................... 10
4.1.1 NORM Competent Persons ........................................................................................................... 10
4.1.2 Radiation Protection Supervisors (RPSs)....................................................................................... 10
4.1.3 Senior Radiation Protection Supervisor (Senior RPS) ................................................................... 10
4.1.4 Radiation Focal Points (RFPs) ........................................................................................................ 11
Training and Competence ..................................................................................................................... 11
4.2.1 NORM Awareness Training ........................................................................................................... 11
4.2.2 RPS Basic Training ......................................................................................................................... 11
4.2.3 RPS Refresher Training.................................................................................................................. 12
4.2.4 Radiation Awareness Training for Managers ................................................................................ 12
Appointed Radiation Workers .............................................................................................................. 12
4.3.1 Radiation Protection Adviser ........................................................................................................ 12
4.3.2 Radiation Focal Points and Senior RPS.......................................................................................... 12
4.3.3 Appointment of Radiation Protection Supervisors ....................................................................... 12

5. NORM MANAGEMENT .......................................................................................... 14

Origin .................................................................................................................................................... 14
Definition of NORM Contaminated ...................................................................................................... 15
NORM Monitoring ................................................................................................................................ 15
On-Site Storage of NORM Contaminated Equipment/Material ........................................................... 17
Storage of NORM Contaminated Equipment/Material at RWC ........................................................... 18
Control of NORM Contaminated Equipment ........................................................................................ 18
Worker Protection Requirements......................................................................................................... 19

6. INSTRUMENTATION .............................................................................................. 20
Contamination Meters .......................................................................................................................... 20
Dose Rate Meters ................................................................................................................................. 20
Personal Dosimeters ............................................................................................................................. 20
Recommended Meters for Use by ROO Personnel............................................................................... 20
Specialist Survey Equipment ................................................................................................................. 21
Guidance for Determining Background ................................................................................................ 21
6.6.1 Tubular Joints at Well Sites ........................................................................................................... 21
6.6.2 Other Equipment at Well Sites ..................................................................................................... 21
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Management of Naturally Occurring Radioactive Materials
6.6.3 Plant and Process Equipment at the Degassing Stations .............................................................. 21
6.6.4 Equipment in High Background Areas .......................................................................................... 21
6.6.5 Bulk Material – Desludging Activities ........................................................................................... 21
6.6.6 Bulk Material – Land Remediation................................................................................................ 22

7. DOSE ASSESSMENT AND DOSE LIMITS ................................................................... 23

Iraqi and International Dose Limits ....................................................................................................... 23
Classification of Workers ...................................................................................................................... 23
ROO Dose Limits ................................................................................................................................... 24
Hazard Maps ......................................................................................................................................... 24

8. NORM PROCEDURES (SOPS) .................................................................................. 25

9. WORKING WITH NORM FORMS ............................................................................. 67
10. APPENDIX A – RPS LETTER OF APPOINTMENT ........................................................ 81
11. Appendix B – NORM Risk Assessment .................................................................... 82
Risk Assessment for Work with NORM (Excluding Vessel and Tank Entry) .......................................... 82
11.1.1 Assumptions ................................................................................................................................. 82
11.1.2 External Exposure ......................................................................................................................... 82
11.1.3 Internal Exposure .......................................................................................................................... 82
11.1.4 Total Dose from Internal and External Exposure .......................................................................... 83
Risk Assessment for Entry into NORM Contaminated Tanks and Vessels ............................................ 83
11.2.1 Assumptions ................................................................................................................................. 83
11.2.2 External Exposure ......................................................................................................................... 84
11.2.3 Internal Exposure .......................................................................................................................... 84
11.2.4 Total Dose from Internal and External Exposure .......................................................................... 84
ROO Dose Limits ................................................................................................................................... 85

12. APPENDIX C – NORM CONTINGENCY PLANS ........................................................... 86

Spill / Leakage of NORM contamination ............................................................................................... 86
Personal Contamination ....................................................................................................................... 86
Ingestion / Inhalation of NORM ............................................................................................................ 86

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Management of Naturally Occurring Radioactive Materials
1. PURPOSE
The intent of this document is to define the responsibilities of Rumaila personnel and their contracted
service companies when working with and disposing of Naturally Occurring Radioactive Material
(NORM).

The purpose of this guide is to define how to control, store and safely dispose of solid and liquid wastes
produced which contain NORM. The goal is to prevent oilfield worker exposure from inhalation and
ingestion of NORM dust or particulate, and to help ensure that NORM-contaminated equipment is not
sent out for repair, released for use or sold as scrap metal with the potential to expose subsequent
handlers or the public.

Occasionally there will also be an external radiation hazard associated with NORM due to gamma
radiation and this document provides guidance on how to identify this and put the appropriate controls
in place.

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Management of Naturally Occurring Radioactive Materials
2. SCOPE
The scope of this document is to ensure that work with NORM is carried out safely and that specific
measures will be taken to comply with statutory controls affecting: -

• Work involving the processing, handling, use, holding, storage, transport, or disposal of NORM

• The preparation of contingency plans to deal with accidents or incidents

This procedure is applicable to all Rumaila personnel involved with NORM at any Rumaila facility.

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Management of Naturally Occurring Radioactive Materials
3. LEGAL AND REGULATORY REQUIREMENTS
This section aims to highlight the relevant legislation, regulations and recommendations for the
management of activities involving NORM. Iraqi legislation takes precedence over the
recommendations of the International Atomic Energy Agency (IAEA) and the transport regulations,
however as a general rule the most restrictive case should always be observed where practicable. A
summary of the Radiation Protection Adviser’s (RPA) recommendations is also given.

Iraqi Legislation
The Iraqi legislation is very sparse with regards to NORM and much of what has been obtained by ROO
is in the form of letters between SOC and the Ministry of Environment. A brief summary of the letters
obtained is given in this section. The piece of legislation that is referenced is the Protection from Ionising
Radiations Law No. (99) of 1980 and Instructions of Determinants of Ionising Radiation Exposure Doses
No. (1) of 2010.

3.1.1 Dose Limits

In Instructions Determinants of Ionising Radiation Exposure Doses No. (1) of 2010 the effective dose
limits are set out. The effective dose limit for a worker, working with radioactive materials or exposed
to radioactive material while working, is 20mSv per year averaged over five years with a maximum of
50mSv in a single year. Limits for equivalent doses to the lens of the eye and the extremities for a
worker are also stipulated. The equivalent dose limit for the lens of the eye is 150mSv in one year and
the equivalent dose limit to the extremities and skin is 500mSv. Dose limits to the public are given as
1mSv for the effective whole-body dose in a single year and 15mSv and 50mSv to the lens of the eye
and the extremities, respectively. A further category of apprentices, trainees and students aged
between 16 and 18 years is given. In this case the annual limits are 6mSv, 50mSv and 150mSv for the
effective whole-body dose, equivalent dose to the lens of the eye and equivalent dose to the extremities,
respectively.

3.1.2 Classification of Radioactive Materials

The classification of radioactive materials is not addressed satisfactorily in the letters between SOC and
the Ministry of Environment. Many of the “determinants” discussed are dependent on the equipment
used to carry out radiation monitoring, and no standard is defined; this makes it impossible to draw a
useful set of limits from the legislation. However, a letter from Bushra Ali Ahmed (a general manager
at the Ministry of Environment) dated the 22nd of December 2011 requests that the literature of the
IAEA is referenced for environmental determinants. This means that the IAEA Safety Standards (see
section 3.2 below) should be followed when classifying radioactive materials until better legislation is
drafted by the Iraqi government.

Recommendations of the RPA

The differences between national legislation and international recommendations can often create
difficulties when trying to achieve compliance and so it is necessary to bring elements from all of the
relevant documents together to ensure compliance across all regulations. The ROO Radiation
Protection Adviser (RPA) recommends the use the IAEA Basic Safety Standards as a standard in
defining controlled and supervised areas and radiation action levels where the national legislation does
not provide sufficient detail.

3.2.1 The IAEA Basic Safety Standards

Iraq has been a member state of the International Atomic Energy Agency (IAEA) since 1959 and thus
its legislation should be aligned with the recommendations of IAEA. The IAEA Safety Standards series
provides a comprehensive overview of the requirements of an effective system of radiological protection
through the various General Safety Requirements.

The recommendations of the IAEA are far more detailed than the Iraqi legislation with respect to
classing naturally occurring material as radioactive. The IAEA stipulates that if any of the radionuclides
from the uranium or thorium decay chains present in a material (see section 5 about NORM) has an
activity concentration exceeding 1Bq/g then that material is radioactive.

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Management of Naturally Occurring Radioactive Materials
The IAEA documents also convey the idea of exemption levels below which materials should be subject
to fewer restrictions and less regulatory control.

The dose limits outlined by the IAEA are mostly the same as those in use in Iraq with the exception of
the limits on doses to the lens of the eye. The latest IAEA recommendations restrict the dose to the
lens of the eye further than before. The equivalent dose limit for the lens of the eye is 20mSv per year
averaged over five years with a maximum of 50mSv in a single year.

The classification of areas as controlled or supervised is given in qualitative terms in the IAEA Safety
Standards as below.

For controlled areas:

• Registrants and licensees shall designate as a controlled area any area in which specific
measures for protection and safety are or could be required for:

• Controlling exposures or preventing the spread of contamination in normal operation;

• Preventing or limiting the likelihood and magnitude of exposures in anticipated operational

occurrences and accident conditions.

For supervised areas:

• Registrants and licensees shall designate as a supervised area any area not already
designated as a controlled area but for which occupational exposure conditions need to be kept
under review, even though specific measures for protection and safety are not normally needed.

The transport of radioactive material is covered by the IAEA Regulations for the Safe Transport of
Radioactive Material; this is covered in section 3.3.

On all ROO Sites, all areas in which the dose rate is equal to or greater than 7.5µSv/h be designated
as Controlled Areas. The inside of tanks and vessels should be assumed to be Controlled Areas until
measurements can prove otherwise. All other radiation areas are Supervised Areas unless assessed
otherwise by the ROO Radiation Protection Supervisor (RPS).

Transport Regulations
As Iraq is a member state of the IAEA, the transport of radioactive material within, into and out of Iraq
should be compliant with the regulations set out in the IAEA Regulations for the Safe Transport of
Radioactive Material (2012 Edition), Specific Safety Requirements SSR-6. The transport of radioactive
materials by ROO will generally be by road. Transport by any other means is not covered by this
document and, if required, must be discussed with the RPA.

There is currently no approved guidance publication for transport of radioactive materials by road in
Iraq, but all consignments must comply with the IAEA Regulations and the local legislation. Consigning
radioactive material in agreement with the legislation can be difficult without an approved guidance
publication; however, the European Agreement Concerning the International Carriage of Dangerous
Goods by Road (commonly referred to as ADR) is based on the IAEA Regulations and can therefore
be used as a rough guide. Ultimately it is the local legislation and the IAEA Regulations that must be
adhered to.

Guidance on how to transport NORM waste and samples can be found in SOP07 and SOP08 at the
end of this document.

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Management of Naturally Occurring Radioactive Materials
4. RADIATION MANAGEMENT OVERVIEW
This section provides an overview of radiation management by identifying the individual roles and
responsibilities. The details of the appropriate training to be provided are also described.

Overall management of NORM issues and custody of the Rumaila NORM Policy lies with the Radiation
Protection Team within the Health Department. All ROO staff and contractors are responsible for
understanding and complying with the Rumaila NORM Policy. For assistance with pre-job planning or
further information contact the Senior RPS at [email protected].

Roles and Responsibilities

It is important that everyone involved in the management of NORM has the necessary competence and
awareness of the hazards, systems, procedures and relevant legislation surrounding NORM and
ionising radiations. The structure of a radiation management system involves a hierarchy of roles
covering all activities on the sites involving radiation. The level of training required for each role varies
depending on the degree of involvement with radioactive substances that person is expected to have
and their areas of responsibility within the organisation.

4.1.1 NORM Competent Persons

NORM Competent Persons must have a basic awareness of the hazards associated with ionising
radiations and the measures in place to minimise doses to personnel. This awareness is achieved
through the NORM Awareness Training course (see 4.2.1). NORM Competent Persons must be
competent in the operation of the appropriate meters (contamination and dose rate meters) and this
competency is achieved through a combination of classroom based teaching and practical, on-the-job
training. Competency is assessed via a written examination and a practical assessment. Only those
whose competency as a NORM Competent Persons has been recognised and recorded in their ROO
Safety Passports are permitted to carry out radiation tests. Refresher training must be carried out within
two years. The NORM Competent Persons answer to the Radiation Protection Supervisor (RPS) and
make measurements on his behalf. The RPS must therefore have a role in choosing the persons
identified as NORM Competent Persons.

The NORM Competent Persons must have the authority to stop work, on behalf of the RPS, should a
positive level of NORM or a higher than acceptable dose rate be found.

4.1.2 Radiation Protection Supervisors (RPSs)

RPSs must have a good understanding of the sources of radiation (sealed sources and/or NORM as
necessary), the hazards associated with each source, and the measures taken to minimise doses to
personnel. This level of understanding is achieved through two to five days (depending on duties) of
classroom-based training carried out by the Radiation Protection Adviser (RPA). The RPS should also
attend a refresher course within two years of their full course. The RPS must also be competent in the
operation of the appropriate meters (contamination and dose rate meters) and is responsible for the
training of NORM Competent Persons with their line department and ensuring that meters have valid
calibration certificates. The RPS is responsible for all radiation activities that are being carried out within
their respective department and should be familiar with all of the requirements in this document relevant
to their work. The RPS answers to the Radiation protection team leader.

4.1.3 Radiation Protection Team Leader

The Radiation protection team leader must undergo the same training regime as the other RPSs but
has a broader scope of responsibilities. The Radiation protection team leader is responsible for
ensuring that all RPSs have the appropriate training and all records of training are available on site
(training certificates, letters of appointment etc.). It is important for the Radiation protection team leader
to have a strong familiarity with the requirements of this document as they are responsible for
supervising the day-to-day running of all radiation activities for the entire field. It is therefore important
for the Radiation protection team leader to establish good communication with the other RPSs and
NORM Competent Persons. The Radiation protection team leader also acts as a link between the
operational personnel involved with ionising radiations (RPSs and Radiation Meter Users) and the

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Management of Naturally Occurring Radioactive Materials
Radiation Focal Points (RFP) and RPA. Thus, the Senior RPS must report any issues that could lead
to an unnecessary dose. The Senior RPS answers to the RFPs and the RPA.

4.1.4 Radiation Focal Points (RFPs)

The RFP must have a good awareness of matters involving ionising radiation which can be achieved
through informal and formal training provided by the Radiation Protection Adviser (RPA). The RFP
must establish good communication with all RPSs (particularly the Radiation protection team leader) to
ensure that any issues with regards to radiation are addressed. It is important that the RFP has a
sufficiently senior position within the company to allow them to approach senior management directly if
required. The RFP acts on behalf of ROO Senior Management.

Training and Competence

There are various levels of knowledge required by different personnel involved in the management and
safe operation of work involving ionising radiation.

The key training requirements required for different levels of responsibility are highlighted below.

4.2.1 NORM Awareness Training

This course is primarily aimed at those with an active involvement in the detection and monitoring of
NORM, i.e. NORM Competent Persons. Following this training the delegates should;

• Understand the risks associated with ionising radiation

• Have a basic understanding of the origin of NORM in the oil and gas industry; where and how
it occurs

• Have an awareness of the legislation and its application to working with NORM

• Be competent in planning work where NORM is expected

• Be competent in choosing the most suitable meter for a job

This course is generally delivered by one of the ROO RPSs and constitutes the ROO Level 2 Basic
User Training. A curtailed variant of this course is available for personnel who will not be operating the
radiation meters (Level 1).

4.2.2 RPS Basic Training

Anyone wishing to be appointed as an RPS must undergo a basic training course, lasting between two
and five days depending on the delegates’ responsibilities. The course covers;

• Basic physics and radiobiology of ionising radiation

• Sealed sources

• NORM

• Radiation instruments

• Personal dosimetry

• Transport of radioactive substances

• Emergency response

• Legislation

• Roles and responsibilities of the RPS

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Management of Naturally Occurring Radioactive Materials
This course is assessed by a short examination and delegates will be awarded a certificate of
competence upon successful completion of this examination.

4.2.3 RPS Refresher Training

This one-day refresher course must be undertaken biennially following completion of the RPS Basic
Training. This course covers;

• Recent changes in legislation

• Updates to the radiation management system and procedures

• Recent developments in sealed source technologies

• Recent developments in the available disposal routes for NORM waste

• Recent incidents and trends

An extension to the RPS certificate of competence will be granted to the successful delegate.

4.2.4 Radiation Awareness Training for Managers

This is a one-day course aimed at site managers and RFPs. This course helps those with a less
operational role within the radiation management structure to understand the problems associated with
ionising radiation. It also helps consolidate the issues and responsibilities of the management of
ionising radiation. The course covers;

• The health, safety and environmental risks of ionising radiation

• Sealed sources

• NORM

• Legislation and regulation

• Responsibilities of the operator management

• Recent incidents and trends

Appointed Radiation Workers

4.3.1 Radiation Protection Adviser

To meet local and international radiation requirements a Radiation Protection Adviser must be
appointed to support ROO operations.

Surat Al Tawseel for General Trading Services and Equipment Leasing

4.3.2 Radiation Focal Points and Radiation Protection Team Leader

The ROO Radiation Focal Point for all matters relating to radiation including NORM is the Radiation
protection team leader (e-mail contact – [email protected],
[email protected] ).

4.3.3 Appointment of Radiation Protection Supervisors

Before anyone can act as an RPS they must be appointed by one of the RFPs in writing. An example
letter of appointment is given in section 10.0. A list of all appointed RPSs and their area of responsibility
(e.g. ‘Markazia’ or ‘All Sites’) should be held by the Radiation protection team leader.

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Management of Naturally Occurring Radioactive Materials
It is the responsibility of the RFP to ensure that the appointee has successfully completed an
appropriate RPS training course given by a competent training provider. This training must provide
sufficient information on the relevant legislation and regulations.

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Management of Naturally Occurring Radioactive Materials
5. NORM MANAGEMENT
Origin
Much of the plant and process on the degassing stations may become internally contaminated with
NORM during operation. Additionally, much of the production well tubulars and equipment may become
contaminated with NORM once reservoir fluids have flowed through them. Therefore, work which
involves maintaining, repairing or exposing internal surfaces of the production processes must be tested
at an early stage for the presence of NORM. Where NORM is identified, procedures are put in place to
ensure that personnel are not exposed to NORM in ways, which may be hazardous to health.

Figure 5.1.1 – The origins of NORM

Gas Sphere

Crude Oil
Tank
Gas / Oil Separator

Produced
Water Tank

NORM in Scale

NORM in Gas

NORM in Reservoir Fluids

Work on NORM contaminated equipment may be carried out by appropriately trained and equipped
Site personnel or by a specialist contractor.

NORM scale is normal oilfield scale, which is usually calcium or barium sulphate and/or carbonate,
contaminated with uranium/thorium progeny elements, making the scale radioactive. These elements
occur naturally at trace levels but can become concentrated in the scale.

Oil and produced water systems will tend to be contaminated with Radium-226, Radium-228, and
daughters.

Natural gas systems may be contaminated with Lead-210 and Polonium-210. The NORM
contamination found in gas systems, may not be present as a visible scale or deposit. The
contamination may be present as a thin layer or ‘sheen’.

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The activity levels currently found in NORM scale are such that external radiation fields around scaled items
are generally low, but it should be noted that localised high dose rates can be found. The primary hazard is
an internal hazard resulting from inhalation and/or ingestion of NORM scale.

Figure 5.1.2 – Example of NORM contaminated scale

Definition of NORM Contaminated

Pieces of equipment with formed scales that give a reading on a contamination meter of 3 counts per
second or more above background are considered to be contaminated. This limit gives a reasonable
indication that the activity of any naturally occurring radionuclide (e.g. Ra-226) may be in a
concentration greater than 1Bq/g which is the limit stipulated by the IAEA. Sands and sludges from
vessels are also considered to be contaminated if they give a reading on an appropriate contamination
meter of 3 or more counts per second above background. The threshold of 3 counts per second above
background also applies to personal protective equipment (PPE). If PPE gives a reading on an
appropriate contamination meter above this threshold, then it must be considered as radioactive waste.

NORM Monitoring
NORM monitoring should be carried out by NORM Competent Persons and / or RPSs using the
recommended meters (see section 6) and a record of all monitoring must be kept using the appropriate
Form NORM01 – Record of Work Involving NORM. Details of all NORM contaminated items and
material must be recorded on the associated Form NORM01 and details of where NORM waste is
stored should be recorded in the comments section of Form NORM01. This system helps to ensure
traceability for all jobs where there is potential for NORM.

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Figure 5.3.1 – Schematic of surveying for NORM

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Management of Naturally Occurring Radioactive Materials
On-Site Storage of NORM Contaminated Equipment/Material
Highlighted below are key instructions to ensure storage of NORM contaminated equipment is carried
out safely and in compliance with local regulatory requirements.

A suitably marked and labelled NORM Store must be constructed on each site where NORM is found
to allow for any potential NORM contaminated material/equipment to be stored appropriately. The
NORM Store should be established as early as possible prior to any operations that may produce
NORM contaminated equipment. The designated NORM Store should be indicated on the relevant
hazard map for the site in Control of Work all NORM for the site should be stored in this area unless
otherwise agreed with the ROO Radiation protection team leader. The NORM Store must satisfy the
following criteria:

1) Position well away from other major hazards such as fire hazards, explosives or corrosives

2) Only NORM Contaminated material and items may be kept in the NORM Store; if an item is
non-contaminated it must be removed from the Store at once

3) The walls must restrict access but be easily decontaminated

4) All sides of the store must be marked in English and Arabic to indicate that it is the NORM Store
with the words ‘Radioactive Material’ and the radiation trefoil as a minimum

5) The floor of the NORM Store must be constructed in such a way that it prevents any leakage
of material and is easily decontaminated

6) Material and equipment must be stored in an orderly fashion to allow for quick identification of
items and to assist in inventory checks

An inventory of all equipment and material held in each NORM store must be kept up to date using
Form NORM02 – Temporary NORM Store Inventory and a periodic check of this inventory should be
carried out by contractor or Rumaila Waste Centre RPSs . NORM waste should be removed from the
site for temporary storage at the Rumaila Waste Centre (RWC) as soon as reasonably practicable and
ideally should not be on the Site for more than 2 months. Ultimately, waste will be removed from the
RWC for final disposal at a later date. Contact the ROO HSE Rumaila Waste Centre Coordinator
([email protected]) for guidance on arranging temporary storage at the RWC.

All equipment in the NORM Store must be labelled as NORM contaminated using yellow/black “NORM
Contaminated” tape and tags. Any equipment that has been found not to be NORM contaminated
should be labelled as NORM free on all accessible surfaces using green/black “NORM Free” tape and
tags. See figures 5.4.1 and 5.4.2 below.

Figure 5.4.1 – ‘NORM Contaminated’ and ‘NORM Free’ tags with English and Arabic

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Loose sludges, scales and sands should be placed in thick plastic bags (preferably double bagged) and
placed inside clip top drums. The drums must be labelled in the same way as equipment for NORM
contaminated and non-contaminated material. A single drum must not contain mixed waste, i.e. a bag
of NORM contaminated material and a bag of non-contaminated material.

To aid in the traceability of equipment and material that has been checked for NORM contamination the
tags used should contain the following information as a minimum:

• Origin of item/waste, i.e. area of plant where the item/waste was found

• Name of RPS

• Date

• NORM Job Number

• Description, e.g. 10” produced water spool

Storage of NORM Contaminated Equipment/Material at RWC

The following points should be used as a general guide on how to store NORM contaminated equipment
and material for the medium to long term at the Rumaila Waste Centre (RWC).

• Each area used for storing NORM at the RWC must be exclusively used for NORM, i.e. no
other type of material may be stored in the same area.

• NORM storage areas must be designated as Supervised Areas unless the dose rate inside
exceeds 7.5µSv/h, in which case it must be designated as a Controlled Area.

• NORM storage areas must be physically demarcated with a hard barrier / fence with a lockable
gate unless otherwise agreed with the RPA for access reasons (e.g. forklifts / cranes).

• The ground must be of a construction that is easily decontaminable.

• All sides of the store must be marked in English and Arabic to indicate that it is the NORM Store
with the words ‘Radioactive Material’ and the radiation trefoil as a minimum.

• Where possible, containers of NORM susceptible to damage from UV (e.g. plastic drums)
should be protected from direct sunlight.

• An inventory of each NORM storage area must be kept up to date, providing a description of
material and equipment received, the date it was received and the date it was removed.

• Material and equipment must be stored in an orderly fashion to allow for quick identification of
items from specific consignments and to assist in inventory checks.

• Periodic inventory checks must be carried out to ensure the inventory matches what is in each
store. The condition of containers should also be reported as part of these checks to allow
repackaging where necessary before significant leakage can occur.

Control of NORM Contaminated Equipment

Cleaning of NORM contaminated equipment onsite should only be performed after consulting the RPA
and the site HSE Adviser. The work must be carried out in accordance with SOP09 at the end of this
document.

If equipment is found to be NORM contaminated, then all open ends must be covered by wrapping them
in plastic sheeting (1000-gauge 250 micron) and secured using yellow/black NORM Contaminated tape
and tags attached as per section 5.4. Additional tape may be used to make it clear that the equipment
is contaminated. Where possible, at least two tags should be secured to the equipment using tie wraps.

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Items which have been checked and found not to contain NORM scale can be sent to the owner,
refurbishment company, or if appropriate, to the scrap system. Green NORM Clear (all accessible
areas) tape and tags should be attached to these items before sending offsite.

If any loose scale falls out of an item prior to sealing, it must be inserted back into the item, which should
then be sealed as above. If several similar items are being handled, the scale need not necessarily go
into the exact item it came from if it is easier to put it into another in the same batch.

Worker Protection Requirements

There are a number of measures in place with the purpose of minimising the doses received by
personnel working with NORM. These are listed below and must be observed in order to keep doses
as low as reasonably practicable.

• All personnel working in the affected area must wear the following Personal Protective
Equipment (PPE)

o Tyvek style impervious suit

o Impervious / rubber gloves

o Impervious / rubber boots

o A “face fitted” respirator to EN149FFP3 (or NIOSH N100) where possible (e.g. 3M
8835), if these cannot be sourced then EN149FFP2 (or NIOSH N95) must be used as
a minimum

o Safety goggles or safety glasses

• All personnel involved should have the appropriate level of NORM awareness training before
carrying out any work in the affected area

• A record (name, date and time) of all personnel entering and leaving the affected area should
be kept with the rest of the paperwork for the job

• Smoking, chewing gum and the consumption of food and drink are absolutely prohibited in the
affected area without exception; drinking arrangements during summer must be planned
carefully

• The number of personnel working in the area should be kept to a minimum, i.e. essential
personnel only

• PPE should be easily decontaminable to minimise the creation of waste PPE

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6. INSTRUMENTATION
There are various handheld meters available for the purpose of monitoring radiation, each with different
benefits. A summary of the recommended meters can be found in table 6.4.1 below. All meters must
be calibrated every two years by an approved laboratory and a copy of the calibration certificate must
be held at the site at which the meter is to be used.

Contamination Meters
Contamination meters allow the user to measure the rate of radioactive decay incident on the probe in
counts per second (cps). The two types of contamination meter considered are those with Geiger-
Muller end window (GM) type probes and those with scintillation type probes. The GM type is sensitive
to alpha and low energy beta radiation making it ideal for gas systems. The GM type detector works
optimally under dry conditions, e.g. dry contaminated scales, this is because the alpha and low energy
beta radiations do not penetrate a thin layer of oil or water. The scintillation type meter is sensitive to
gamma and high energy beta radiation making it ideal for oil, wax and produced water systems.

Dose Rate Meters

Dose rate meters allow the user to instantaneously measure the dose rate in micro Sieverts per hour
(µSv/h). It is recommended that the dose rate is measured if a result of >200cps above background is
measured when monitoring for NORM. Dose rate measurements are also required for certain work
scopes, e.g. vessel cleaning operations and remediation, as outlined in the relevant SOPs at the end
of this document.

Personal Dosimeters
Personal dosimeters are usually small detectors designed to passively monitor the dose accumulated
by the user. Some ROO personnel are issued with Instadose dosimeters which are managed by the
Industrial Hygiene department. Readings must be taken at monthly intervals and the doses are
monitored by the RPA.

Recommended Meters for Use by ROO Personnel

There are currently four recommended meters for carrying out radiation measurements by ROO
personnel (three contamination meters and one dose rate meter), and these are summarised in table
6.4.1 below. The T407 meter (also referred to as the NORM Monitor - IS) comes with two
interchangeable probes, one GM type and one scintillation type, and a flow chart describing its operation
is found in figure 6.4.1 below.

Model Meter Type Probe Type Suitable For

Tracerco T407* with SA-49

Contamination Geiger-Muller Gas systems
probe

Tracerco T407* with SA-50 Oil and produced water

Contamination Scintillation
probe systems

Tracerco T201 Contamination Geiger-Muller Gas systems

Tracerco T202 Dose rate Dose rate measurements

*The T407 is also referred to as the NORM Monitor - IS

Contractors working on ROO operated sites who supply their own monitoring equipment may use
different instruments to those specified in table 6.4.1 and it is recognised that there are adequate
alternatives available on the market. However, any concerns regarding unfamiliar radiation instruments
being used by contractors should be reported to the ROO RPA who will determine their adequacy. In
order to do this the RPA must be provided with the instrument model (e.g. Tracerco T201) and the
purpose for which it is being used (e.g. dose rate monitoring for radiography).

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Specialist Survey Equipment
In addition to the monitoring equipment mentioned in 6.4 above, ROO also holds several specialist survey
instruments. The model currently held is the Georadis RT-30 which contains a large (51 x 51mm) NaI
scintillation crystal and has gamma spectrometry capabilities. The outputs which can be obtained from this
instrument include counts per second (cps), dose and dose rate (µSv and µSv/h, respectively), a gamma
energy spectrum and the identification of isotopes present. This instrument is not to be used for routine
NORM monitoring but is reserved for specialist work under instruction of the RPA.

Guidance for Determining Background

The determination of the background level of radiation is very important when monitoring for NORM as it can
have a significant impact on the results. The background is easier to determine on some sites than others
and so a rough overview of how to determine the background in different situations is given below.

6.6.1 Tubular Joints at Well Sites

This is the most straightforward situation in Rumaila as the results tend to be very stable. The
method to be used involves taking the background measurement inside a short clean section of
pipe; the SA-50 probe should be inserted into the clean pipe so the measurement windows at the
end are completely covered. This method is used to replicate the background conditions present
when the actual measurements are taken.

6.6.2 Other Equipment at Well Sites

For other equipment at well sites (e.g. valves or trees) the background should be taken in
accordance with 6.6.3 below.

6.6.3 Plant and Process Equipment at the Degassing Stations

On the degassing stations the background will vary across the site but should be relatively stable
in small areas. For this reason, it is important to take your background reading in the vicinity of the
item you are monitoring (roughly 2m away). If another item is to be checked in a different area,
then the background should be measured again.

6.6.4 Equipment in High Background Areas

This is perhaps the most difficult situation to determine a suitable background in as fluctuations will
be high. The background should be taken in the same way as 6.6.3 above and if the item has high
activity NORM contamination on it then the resultant measurements should make it very clear that
it is contaminated. However, in more borderline cases it may be difficult to determine whether or
not a positive reading is due to the presence of NORM or a fluctuation in the background. If the
item must remain in situ then the best approach is to take the background reading as per 6.6.3 and
then take multiple readings using the integrate function on the T407 monitor; if you are still unsure
whether or not to determine the item as NORM contaminated then it should be treated as
contaminated until it can be checked again in a lower background area, if it cannot be removed to
a lower background area then it should continue to be treated as NORM contaminated. Items that
do not have to remain in situ should be removed to a lower background area if there is uncertainty
about whether or not they are NORM contaminated, once in a low background area follow the
protocol of 6.6.3.

6.6.5 Bulk Material – Desludging Activities

For desludging activities, the background should be taken in a low background area on the same
site, e.g. at the main gate to the facility. Measurements of material inside vessels can initially be
made externally as this will often give an indication of the presence of NORM. If this results in a
reading of less than 3 cps above background, then a measurement should be made again upon
initial entry to the vessel.

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6.6.6 Bulk Material – Land Remediation
For remediation projects the background should be taken in a low background area well away from
the contaminated land and the protocol outlined in SOP10 should be followed for NORM
identification. The offices usually provide an adequate location to measure the background and
carry out the monitoring protocol outlined in SOP10.

Operation of
Monitor

1. Check background based on the guidance in

section 6.5 above by pressing the “Log
Background” button and waiting approximately
60 seconds until the red light flashes.

2. Press (do not hold) the coloured button (see

right) so the green light flashes. If necessary,
press the “Mode” button repeatedly until the

3. Position the probe at the point of

measurement and press (do not hold) the
coloured button (see right).

4. Hold the probe in position until the red light

flashes and the monitor generates a sound; the
length of time this takes will depend on how
that unit has been set up; contact the ROO

Is the
No reading Yes
equal to or
greater than

Non- Contaminated
contaminated
Figure 6.4.1 – Instructions on the use of the T407 monitor

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7. DOSE ASSESSMENT AND DOSE LIMITS
A full radiological dose assessment has been prepared and can be found in Appendix B of this
document (section 12.0). The radiological dose assessment makes pessimistic assumptions about the
work involving NORM that ROO personnel are engaged in to obtain an upper limit on the potential
annual whole-body doses. The doses arrived at have been used as the basis of self-imposed dose
limits, going beyond the legal requirements and affording personnel a high standard of radiation
protection. Due to the differences in exposure between entry into NORM contaminated vessels / tanks
and other NORM work at ROO, these two types of worker have been treated separately. This section
outlines the dose limits that have been set and puts them into the context of local requirements,
international standards and best practice.

Iraqi and International Dose Limits

In Iraq, the effective whole-body dose limit for a worker, working with radioactive materials or exposed
to radioactive material while working, is 20mSv per year averaged over five years with a maximum of
50mSv in a single year. Limits for equivalent doses to the lens of the eye and the extremities for a
worker are also stipulated. The equivalent dose limit for the lens of the eye is 150mSv in one year and
the equivalent dose limit to the extremities and skin is 500mSv. Dose limits to the public are given as
1mSv for the effective whole-body dose in a single year and 15mSv and 50mSv to the lens of the eye
and the extremities, respectively. A further category of apprentices, trainees and students aged
between 16 and 18 years is given. In this case the annual limits are 6mSv, 50mSv and 150mSv for the
effective whole-body dose, equivalent dose to the lens of the eye and equivalent dose to the extremities,
respectively.

The only difference between the Iraqi annual dose limits and those set out in the International Atomic
Energy Agency’s (IAEA) Basic Safety Standards is that the limits on doses to the lens of the eye are
lower, 20mSv for a worker and 15mSv for a member of the public. The Iraqi and IAEA dose limits are
summarised in tables 7.1.1 and 7.1.2 below.

Iraqi Annual Dose Limits (mSv) IAEA Annual Dose Limits (mSv)
Body Part Trainees Members Body Part Trainees Members
Workers Workers
(aged 16 to 18) of Public (aged 16 to 18) of Public
Whole-Body 20 6 1 Whole-Body 20 6 1
Lens of Eye 150 50 15 Lens of Eye 20 20 15
Extremities or Skin 500 150 50 Extremities or Skin 500 150 50
Table 7.1.1 – Summary of legal dose limits in Iraq Table 7.1.2 – Summary of dose limits stipulated by the IAEA

Classification of Workers
A system which is alluded to in the IAEA Basic Safety Standards is that of classification of workers, a
system which has been fully implemented across Europe. Classification of workers introduces two
types of employee who work with ionising radiation; Category A and Category B workers. Category A
workers are those who are likely to receive higher doses from ionising radiations as part of their work
and Category B workers are those who are routinely exposed to ionising radiations as part of their work
but whose potential doses are generally lower. The structure for classification of workers is outlined in
table 7.2.1. This structure ensures that stricter limits are imposed in most cases where employees are
required to work with ionising radiations.

annual dose limits (mSv)

Body Part
Category A Workers Category B Workers
Whole-Body 20 6
Lens of Eye 20 15
Extremities or Skin 500 150
Table 7.2.1 – Summary of example dose limits for classification of workers

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ROO Dose Limits
Based on the radiological dose assessments carried out (see Appendix B, section 12.0), two separate
dose limits have been set for ROO personnel – one for those workers entering NORM contaminated
tanks and vessels and one for other workers. The highest doses accrued when working with NORM
are generally whole body doses and therefore dose limits have only been set for whole-body exposures
on the assumption that doses to the extremities, skin and lens of the eye will be lower.

No ROO personnel working with NORM are classified as Category B workers as the potential doses
within the confines of the SOPs in this document are not high enough to warrant classification.

The ROO dose limits are summarised in Table 7.3.1 below.

annual whole-body
Personnel
dose limit (mSv)
Personnel working inside NORM contaminated tanks and vessels 4
Other personnel working with NORM 1
Table 7.3.1 – Summary of ROO dose limits

Hazard Maps
Every single degassing station has a hazard map associated with it in Control of Work. These hazard
maps demonstrate which areas are designated as radiation areas as well as showing other hazardous
areas. These maps should be checked before carrying out any work to ensure any required NORM
control measures are put in place prior to commencement. An example of such a hazard map is given
in figure 7.4.1 below.

Figure 7.4.1 – Example of a hazard map

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8. NORM PROCEDURES (SOPS)
The following SOPs have been developed to facilitate the most common operations involving NORM
on ROO-operated sites. These SOPs are designed to be used as standalone procedures by personnel
involved in working with NORM and must be adhered to at all times. If, for any reason, the requirements
of the SOPs cannot be fulfilled then the RPTL, RFP and RPA must be contacted to determine how work
should proceed.

The full list of NORM SOPs is as follows:

SOP01 – Identifying and Handling of NORM Contaminated Plant and Process Equipment (Not
Involving Vessel Entry)
SOP02 – Entry and Cleaning of NORM Contaminated Tanks and Vessels

SOP03 – Identifying and Handling of NORM Contaminated Tubulars

SOP04 – Handling of Potentially NORM Contaminated Coiled Tubing

SOP05 – Handling of Potentially NORM Contaminated Downhole Tools (Including Nuclear Logging
Tools)
SOP06 – Milling of NORM Scale and Handling NORM Contaminated Fluids

SOP07 – NORM Sampling Methodology and Consignment

SOP08 – Transportation of NORM Waste

SOP09 – Decontamination of NORM Contaminated Items on the Site

SOP10 – Working with NORM (Remediation Projects)

SOP11 – Preparation of Ground Pads

SOP12 – Instructions for UXO Teams Working in NORM Contaminated Areas

SOP13 – Management of NORM at the Rumaila Waste Centre

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SOP01 - Identifying and Handling of NORM Contaminated Plant and Process Equipment (Not
Involving Vessel Entry)

Intent

The intent of this standard operating procedure is to describe the actions required to identify, handle,
and dispose of Naturally Occurring Radioactive Material (NORM) Contaminated Plant and Process
Equipment (Not Involving Vessel Entry). This SOP also applies to remote operations, e.g. removal /
replacement of equipment by Well Services.

Much of the process plant at Rumaila may be internally contaminated with NORM sand, scale or sludge.
Therefore, work which involves maintaining, repairing or exposing the internal surfaces of the process
systems must include a NORM check at an early stage. Where NORM is identified, procedures must
be put in place to minimise the risks to workers due to NORM.hot oil exposed items is not included,break
in containment may go without a NORM checking, full PPE listed below is recmmonded for more
precautions.

Roles and responsibilities

1. NORM competent person (personnel who have successfully completed the ROO level 2 basic
user training) - Carry out site radiation measurements as requested.

2. Radiation Protection Supervisor (RPS) (personnel who have successfully completed an RPS
training course) – The role of the RPS is to control all work where NORM contamination has
been determined. The ROO RPTL can be contacted on ([email protected]).

Procedure

1. Preparation for Work

Before starting a job where there is a potential for NORM contamination, it is important that the
workforce and worksite are prepared. It is essential that all personnel are briefed on the hazards
associated with NORM during any toolbox talks.

The following equipment should be available before work starts:

a. ‘NORM Contaminated’ tape and tags

b. ‘NORM Free’ tape and tags

c. ‘NORM Supervised Area’ signs

d. Barriers (scaffold or chains)

e. Contamination monitor (T407 c/w SA-50 and SA-49 probes)

f. Dose rate monitor (T202)

g. P3-rated respirator (e.g. 3M 8835)

h. Rubber/PVC boots and gloves

i. Tyvek disposable coveralls

j. Shallow water bath for cleaning contaminated boots and other PPE

k. Heavy duty (1000-gauge 250 micron) polythene sheeting

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2. Identification and early management of identified NORM

a. NORM may be found anywhere in the process that has been exposed to fluids or gas,
so it is important that monitoring is carried out before working on plant/process
equipment.

b. There are two types of contamination monitor and one type of dose rate monitor
available at Rumaila; these are detailed in the table below.

c. Form NORM01A – Record of Work Involving NORM must be completed for every job
requiring a NORM check.

d. When monitoring for NORM contamination a measurement of 3 cps (counts per

second) or more above background is considered to be contaminated.

e. If a measurement of 200 cps or more above background is observed, then a dose rate
measurement must be made.

f. If a dose rate of 7.5µSv/h (micro Sieverts) or more is measured in a location that could
lead to a whole body dose, then the job must be stopped and the ROO RPTL informed
(e-mail [email protected]); he will advise on what steps to take.

g. If NORM is identified, then the work area must be designated as a Supervised Area
before work continues and NORM procedures must be put in place (see below).

Monitor Sensitive to Use for

T201 Alpha and Beta Gas systems, dry equipment and confirming external contamination
T407 c/w SA-49 Alpha and Beta Gas systems, dry equipment and confirming external contamination
T407 c/w SA-50 Gamma Oil systems, produced water systems and any wet equipment
T202 Gamma Measuring external gamma dose rate

3. Handling NORM Contaminated Plant and Process Equipment

a. All personnel in a Supervised Area are required to wear the following PPE: One-piece
disposable coverall (e.g. Tyvek), P3-rated respirator, Rubber or PVC boots and gloves
PLUS any other PPE required by the risk assessment.

b. To set up a Supervised Area, barriers should be erected around the work area with
warning signs stating that it is a NORM Supervised Area in English and Arabic.

c. There should only be one entry/exit point and personnel entering the area must be kept
to a safe minimum.

d. Personnel must be signed in and out of the area and checked for contamination before
they leave.

e. Contaminated boots are to be cleaned in a shallow bath and contaminated coveralls

and gloves should be cleaned using a hose if possible.

f. Any PPE which remains contaminated should be placed in a sealed container and
labelled NORM waste, then placed in the on-site NORM storage/laydown area.

g. If water from the bath contains NORM from decontamination at the end of the job then
should also be containerized, labelled, and stored in the on-site NORM
storage/laydown area until final disposal under instruction from the Rumaila Waste
Centre Co-ordinator ([email protected]).

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h. Heavy duty polythene sheeting should be used to cover ground of the entire Supervised
Area. If this is not practical, then polythene sheeting should be placed in areas where
NORM may fall onto the ground as a minimum.

i. Take any slip hazards into consideration when deciding on areas to cover.

j. NORM contaminated equipment must not be allowed to dry out if preventable as this
may lead to NORM dusts being created.

k. Cover all open ends of contaminated equipment with polythene sheeting; if this is not
immediately possible then try to keep the equipment damp. This will reduce any risk of
inhalation of NORM particulate.

l. Items that are to be reinstated which are contaminated but the NORM does not inhibit
their operation do not have to be decontaminated before reinstating.

m. Reinstatement of equipment must be recorded.

n. If grinding or cold cutting operations are to be carried out, PPE and a face-piece
respirator must be worn.

o. If hot cutting is to be carried out, the respirator must be replaced with an air fed
breathing system and RPA should be consulted.

p. Consult the RPS and RPA before any non-routine NORM work is carried out.

4. Labelling and Containment

a. When an item is tested and found to be contaminated with NORM the open ends and
contaminated surfaces must be wrapped with heavy duty polythene and marked with
yellow/black ‘NORM Contaminated’ tape and tags. The tag must have the following
information written on it:

b. Job number and facility name

c. Short description of item/waste

d. cps above background

e. Date

f. Name of meter user or RPS

g. Where an item is found to be non-contaminated it must be marked with green/black

‘NORM Free’ tape and tags. The tags should contain the same information as for
contaminated items (see above).

h. When loose sand, scale or sludge is to be accumulated the RPS must ensure that
suitable packaging/containers are used. Small quantities may be placed in heavy duty
polythene bags which are then sealed using strong tie wraps and black/yellow ‘NORM
Contaminated’ tape and tags. The external surfaces of the bags must be free of NORM
contamination; if they are contaminated then they must be placed inside a secondary
bag. All bags should then be placed inside clip-top drums in the local NORM
storage/laydown area where available.

5. NORM Storage/Laydown Areas

a. Each degassing station at Rumaila should have a suitably demarcated and labelled
NORM laydown area for holding NORM contaminated items/waste prior to disposal,
decontamination or reinstatement. This area should be well away from other major
hazards such as fire, explosives or corrosives and must only be used for storage of
NORM contaminated material.
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b. Unauthorised access to the storage/laydown area must be prevented, for example with
signage and barriers, and the area must be easily decontaminated, i.e. the floor should,
where possible, be made of concrete and not sand.

c. The store must have appropriate warning signs with the radiation trefoil and the words
‘Radiation – NORM Storage Area, No Unauthorised Access’ in English and Arabic.

d. NORM contaminated waste and equipment should be dealt with as soon as practicable
and ideally not held in the storage/laydown area for longer than necessary. Contact the
Rumaila Waste Centre Co-ordinator ([email protected])at least 2
working days ahead of the required transport time for guidance on where to dispose of
NORM contaminated materials before transport off-site.

e. An inventory of the storage/laydown area contents must be kept using Form NORM02
– Temporary NORM Store Inventory and checked periodically.

6. Decontaminating and Reinstating the Worksite

a. At the end of operation all workers must be checked for contamination on their PPE,
particularly the soles of boots.

b. If possible, all clothing, materials and equipment used in work with NORM should be
decontaminated by washing or wiping down and kept for reuse or disposed of as non-
radioactive waste. If this is not possible contaminated clothing, materials and
equipment should be stored in sealed labelled container in the on-site NORM
storage/laydown area and disposed of as NORM waste by an agreed disposal route,
with guidance from ROO Radiation ProtectionTeam Leader.

c. Any wash water should be allowed to settle, solids removed and contained as per 4c
above and the water reintroduced to the process where possible. If this is not possible
then the RPA should be contacted for an alternative.

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SOP02 - Entry and Cleaning of NORM Contaminated Tanks and Vessels

Intent

Process vessels and tanks are prone to build-up of sand and sludge over long periods. This can
interfere with the efficiency of the process and so the vessels are opened periodically and cleaned out.
This usually involves Confined Space Entry and physical removal of the deposits with shovels / spades.
Because process fluids pass through these vessels / tanks it is possible for NORM to precipitate out
into the sand and sludge. This leads to the deposits in the vessels / tanks becoming NORM
contaminated therefore additional control measures must be put in place. Where no NORM deposits
are identified in vessels the controls in this procedure may be relaxed. All other relevant procedures
must be followed.

Roles and Responsibilities

1. Work Party – These workers will carry out the vessel / tank cleaning work. They must all have
received radiation awareness training specific to their work; this is usually delivered by the ROO
RPS. The Work Party may be the ROO Static Team or a 3rd party contractor.

2. Work Party Supervisor – This worker, often the Performing Authority (PA), will make the initial
entry and ensure the correct procedures are followed for all work inside the NORM
contaminated vessel. They will be responsible for NORM measuring and contacting the ROO
Radiation Protection Supervisor (RPS) and ensuring that any additional measurements
required are recorded and reported to the ROO RPS. The Work Party Supervisor must have
successfully completed a curtailed version of the 3-day RPS course focusing entirely on NORM.

3. ROO RPS (personnel who have successfully completed an appropriate RPS training course) –
The ROO RPS will oversee the preparation stage of the work until the responsibility is handed
over to the contractor and act as an interface between the contractor work party and ROO.

Procedure

1. Preparation for Work

Before starting a job where there is a potential for NORM contamination, it is important that the
workforce and worksite are prepared. It is essential that all personnel are briefed on the hazards
associated with NORM and the procedures to be followed during any toolbox talks – this should be
carried out by RPS qualified personnel.

The following equipment should be available before work starts:

a. ‘NORM Contaminated’ tape and tags

b. ‘NORM Free’ tape and tags

c. ‘NORM Supervised Area’ and ‘NORM Controlled Area’ signs

d. Habitat

e. Contamination monitor (T407 c/w SA-50 probe) with extension kit

f. Dose rate monitor (T202) with extension kit

g. 1 x Initialised and assigned Instadose dosimeter per group of persons simultaneously

entering the confined space

h. P3-rated respiratory protection; reusable full-face masks with P3 filter cartridges should
be used

i. Rubber/PVC boots and gloves

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j. Tyvek disposable coveralls

k. Shallow water bath for cleaning contaminated boots and other PPE

l. Heavy duty (1000-gauge 250 micron) polythene sheeting

Note: the above PPE is specific to protecting the workforce from the NORM hazard, if the other hazards
present dictate a higher level of protection then this must be observed.

2. Preparation for Vessel / Tank Entry

Before vessel / tank entry work commences the following steps must be taken:

a. Every effort must be made to flush as much loose material from the vessel / tank as
possible using non-intrusive techniques. The different phases (i.e. solids and liquids)
extracted by flushing must be separated on site wherever possible. Solids must be
decanted into drums lined with heavy-duty polythene. These drums must be placed
into the on-site NORM storage/laydown area until they can be transported to the
Rumaila Waste Centre. Separated wash water should be discharged to a designated
oil pit as agreed with the ROO Environmental Advisor ([email protected] /
07704932982). See sections 4j – 4l and 7 for more information.

b. The Work Party Supervisor must ensure the ROO RPS is contacted 72 hours in
advance to oversee the initial measurement at the site by completing and sending a
Form NORM07 to the ROO Radiation Protection Team Leader– note that the readings
will only be able to take if the vessel / tank is open, has been flushed, and as much
waste as possible has been removed without entering the vessel / tank.

c. Once the vessel / tank has been isolated, flushed, and opened, the Contractor RPS
must use the T407 c/w SA 50 and extension kit to obtain contamination readings inside
the vessel / tank to confirm whether NORM is present.

d. Readings must be obtained from each available manway and the results in counts per
second above background (cps abg) from each measurement location must be
recorded on Form NORM03 by the contractor RPS. External readings at drains should
also be taken and recorded where possible. The ROO RPS may also request the Work
Party Supervisor to take further readings inside the vessel / tank.

e. A basic sketch of the vessel / tank must be drawn in the space provided on Form
NORM03 indicating where each of the readings was taken.

f. If the readings are all less than 3cps abg then this must be indicated in the Pre-Job
Checks section of Form NORM03 by checking the box next to Condition 1. The ROO
RPS and the Work Party Supervisor / PA must sign the declaration in the Pre-Job
Checks section of Form NORM03, accepting the results of the measurements. In this
case the rest of this SOP can be ignored, and work may proceed under normal
Confined Space Entry procedures.

g. If a sustained reading of 3cps abg or more is observed, then the vessel / tank is
considered NORM contaminated and this must be indicated in the Pre-Job Checks
section of Form NORM03 by checking the box next to Condition 2.

h. The Contractor RPS must then use the T202 and the extension kit to obtain dose rate
measurements as far inside the vessel / tank as possible.

i. Readings must be obtained from each available manway and the maximum dose rate
from each measurement location must be recorded on Form NORM03 by the RPS.
External readings at drains should also be taken and recorded where possible. Make
use of the sketch (step e) to indicate where each reading was taken.

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j. If readings are below 7.5µSv/h then check the box next to Condition 3 on Form
NORM03 and proceed to step l, otherwise continue to step k.

k. If the readings are greater than 7.5µSv/h, the contractor should inform ROO RPS to
carry out a radiological dose assessment based on the dose rate readings and the
maximum expected occupancy for any individual inside the vessel / tank. See section
3. Radiological Dose Assessment below for more guidance on this step. In the Pre-
Job Checks section of Form NORM03, the box next to Condition 4 must be checked
and the result of the dose assessment recorded in the space provided, if time limitation
is required then the box next to Condition 5 must also be checked and the time limit
per person recorded in the space provided.

l. The ROO RPS must ensure all the relevant boxes in the Pre-Job Checks section of
Form NORM03 under ‘Recommendations’ are checked then ensure that the
declaration is signed by themselves and the Work Party Supervisor / PA. This
declaration shows that both parties are satisfied with the results of the measurements,
dose assessment (where applicable) and subsequent recommendations for the work
with regards to NORM.

m. One Instadose device must be given to each group of workers simultaneously entering
the vessel / tank such that representative doses can be measured.

n. The ROO RPS must then update the Dose Record spreadsheet (see section 5. Dose
Records).

o. A habitat should be erected around the vessel manway with plastic sheeting on the
ground to prevent contamination spreading.

p. Signs must be on display outside the work area with the radiation trefoil and the words
“NORM Supervised Area” or “NORM Controlled Area” – depending on the
recommendations on Form NORM03 – in English and Arabic.

q. There should only be one entry / exit point and personnel entering the area must be
kept to a safe minimum.

r. All other confined space entry precautions and controls identified in the permit must be
observed throughout the operation.

3. Radiological Dose Assessment

To carry out the radiological dose assessment, a conservative estimate of the total time any individual
will be required to be inside the vessel / tank over the course of the entire job must be obtained from
the Work Party Supervisor. This time estimate must then be multiplied by the maximum dose rate
measured to obtain the maximum potential dose;

Dose (µSv) = Time (hours) × Dose Rate (µSv/h) (Equation 1)

The results of this calculation must be recorded in space provided next to Condition 4 in the Pre-Job
Checks section of Form NORM03.

If the calculated dose is less than 300µSv for a single person over the course of the entire job, then the
work may proceed without any time restriction. If the calculated dose is greater than 300µSv then a
secondary calculation must be carried out to determine the necessary time limitation by dividing 300µSv
by the dose rate;

Time Restriction (hours)=(300 (µSv))/(Dose Rate (µSv/h)) (Equation 2)

This time restriction must also be recorded in space provided next to Condition 5 in the Pre-Job Checks
section of Form NORM03. Note: this is the time restriction for each individual for the duration of the
job.

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If the dose calculated in Equation 1 is less than 300µSv then this must be recorded as the estimated
dose in the Dose Record spread sheet (see 5. Dose Records), otherwise a value of 300µSv should be
recorded in the Dose Record spread sheet.

Once the radiological dose assessment has been completed, the ROO RPS and the Work Party
Supervisor must sign the Pre-Job Checks section of Form NORM03, accepting the results of the dose
assessment.

If the work cannot be completed within the constraints set by the radiological dose assessment,
then the vessel / tank must be flushed further to reduce the dose rates. If this is not possible
then the RPA must be contacted to determine how the work should proceed.

4. Working Inside NORM Contaminated Vessels / Tanks

a. All personnel in a NORM contaminated vessel / tank are required to wear the following
PPE: One-piece disposable coverall (e.g. Tyvek), P3-rated respiratory protection (full-
face mask with P3 filters as a minimum), Rubber or PVC boots and gloves plus any
other PPE required by the Confined Space Entry risk assessment.

b. One person from each group of personnel entering the vessel / tank simultaneously
must wear an Instadose device underneath their disposable coverall.

c. The Work Party Supervisor must take measurements of the dose rate at the beginning
of each shift to determine whether the risk assessment is still applicable. These
measurements must be recorded in the Vessel / Tank Entry section of Form NORM03.

d. In cases where the maximum dose rate measured by the contractor RPS in the initial
assessment was less than 7.5µSv/h, the Work Party Supervisor must notify the ROO
RPS if dose rates greater than 7.5µSv/h are observed during the daily checks.

e. In cases where dose rates were greater than 7.5µSv/h in the initial assessment, the
Work Party Supervisor must notify the ROO RPS if dose rates 20% greater than the
maximum measured by the contractor RPS in the initial assessment are observed
during the daily checks.

f. Upon notification by the Work Party Supervisor, the ROO RPS must use the new dose
rate measurements to carry out another radiological dose assessment (see section 3.
Radiological Dose Assessment) to determine if any additional control measures or time
restrictions need to be imposed.

g. Personnel must be checked for contamination before they leave the work area; this
must be recorded in the space provided for that day in the Vessel / Tank Entry section
of Form NORM03.

h. The Work Party Supervisor must sign-off each daily entry in the Vessel / Tank Entry
section of Form NORM03.

i. Most of the sludge in the vessel / tank should be able to be extracted through the drain
via a vacuum pump. The volume of waste generated must be kept to minimum and
the different phases (i.e. solids and liquids) must be separated on site wherever
possible. Material that cannot be extracted using the vacuum pump must be manually
removed from the vessel / tank.

j. All solids removed from the vessel tank must be decanted into drums lined with heavy-
duty polythene. The polythene must then be sealed using tie wraps and the drums
labelled using yellow/black ‘NORM contaminated’ tape and tags. These drums must
be placed into the on-site NORM storage/laydown area until they can be transported
to the Rumaila Waste Centre. The Rumaila Waste Centre Co-ordinator must be given
at least 2 working days’ notice before any required transport time.
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k. Separated wash water should be discharged to a designated oil pit as agreed with the
ROO Environmental Advisor ([email protected]).

l. All tools used inside the vessel should be cleaned before being removed from the
vessel to avoid waste generation.

m. Contaminated boots are to be cleaned in a shallow bath and contaminated coveralls

and gloves should be cleaned using a hose if possible.

n. Any PPE which remains contaminated should be placed in a sealed container and
labelled NORM waste, then placed in the on-site NORM storage / laydown area.

o. If water from the bath contains NORM from decontamination at the end of the job then
this should also be containerized, labelled, and stored in the on-site NORM
storage/laydown area until final disposal under instruction from Rumaila Waste Centre
Co-ordinator ([email protected]) at least 2 working days before any
required transport time.

5. Dose Records
The Dose Record spread sheet is maintained by the ROO RPS and allows for an overview of an
individual’s cumulative dose for the current year to be reviewed. Each individual working in NORM
contaminated vessels / tanks must have their name, employing company (e.g. BOC or agency) and the
annual dose limit (specified in section 7 of ROO-ALL-HS-PRO-0109) input to the Dose Record spread
sheet. The details of each subsequent job that the individual is involved in must then be recorded
against the same row. Data entry and management of the Dose Record spread sheet is the ROO
RPS’s responsibility.

For each job, the permit number from the WorkSafe system must be entered under the “ID” column. If
a radiological dose assessment was carried out as a result of initial monitoring by the contractor RPS
or as a result of subsequent monitoring by the Work Party, then an entry must be entered under the
“Estimated Dose (µSv)” column. As mentioned in section 3. Radiological Dose Assessment, if the
estimated dose is less than 300µSv then this figure must be used. If the estimated dose is greater than
300µSv a value of 300 should be used as the imposed time restriction will limit the doses to this value.
In exceptional cases, where the RPA has been consulted, a higher value may need to be input. In
cases where the measured dose rates are less than 7.5µSv/h and no additional radiological dose
assessment has been carried out then a value of 150 should be input to the “Estimated Dose (µSv)” as
this is in line with the generic radiological dose assessment in section 7 of ROO ALL HS PRO 0109. If
the value input in the “Estimated Dose (µSv)” column is greater than that quoted in the “Remaining
Dose (µSv)” then the individual may not be able to enter the vessel / tank. If this is the case, bring it to
the attention of the HSE Manager and RPA immediately.

At the end of the job, the Instadose devices must be plugged into a suitable PC and read by the ROO
RPS. The highest result must then be recorded in the “Actual Dose (µSv)” column of the Dose Record
spread sheet for that job for each individual involved in the work. If the readout on the PC is “*mSv”
then the dose is below the lower limit of detection and a dose of 30µSv should be recorded as a worst
case.

6. Management of Resultant NORM Waste

There will be three distinct NORM waste streams from vessel cleaning work:

i. NORM sludge removed from the vessel and decanted into suitable containers.

These containers of waste must be marked for traceability and the Rumaila Waste
Centre Co-ordinator ([email protected]) team must be notified 2
working days in advance so that storage can be arranged. The suitability of the
containers should be agreed between ROO and the contractor prior to work
commencing. The containers used must be robust and leak proof and must be able to
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withstand the conditions of transport. All containers sent to the RWC must be able to
withstand year-round weather conditions in Iraq.

ii. NORM contaminated PPE.

Bags/containers of NORM contaminated PPE must be marked for traceability and the
Rumaila Waste Centre Co-ordinator ([email protected]) must be
notified 2 working days in advance so that storage can be arranged.

iii. NORM contaminated tools and equipment.

NORM contaminated tools and equipment should be cleaned inside the vessel if
possible, to avoid creating additional waste. If this is not possible then contaminated
equipment should be wrapped/contained and the Rumaila Waste Centre Co-ordinator
([email protected]) should then be contacted 2 working days in
advance to arrange for storage. hhhhhh

7. Decontaminating and Reinstating the Worksite

a. If possible, all clothing, materials and equipment used in work with NORM should be
decontaminated by washing or wiping down and kept for reuse or disposed of as non-
radioactive waste. If this is not possible contaminated clothing, materials and
equipment should be stored in sealed labelled container in the on-site NORM
storage/laydown area and disposed of as NORM waste by an agreed disposal route,
with guidance from Rumaila Waste Centre Co-ordinator
([email protected]).

b. The Work Party Supervisor must coordinate with the ROO RPS at the end of the
operation to arrange a Close-Out site visit – 24 hours’ notice should be given to the
ROO RPS.

c. A final set of dose rate readings must be taken inside the cleaned vessel. If there are
dose rates above background present, a description of their location should be
recorded in the Close-Out section of Form NORM03, likewise if there are no dose rates
above background then this should be recorded.

d. A short description of the waste generated and stored on site must be recorded in the
Close-Out section of Form NORM03 (e.g. “15 x 205L drums of sludge, stored in NORM
laydown area on the site”).

e. The Work Party Supervisor must hand over all Instadose devices to the ROO RPS.

f. The Work Party Supervisor / PA and the ROO RPS must both sign the declaration in
the Close-Out section of Form NORM03, accepting that the worksite has been returned
to a satisfactory state, all waste is accounted for and the Instadose devices have been
returned to the ROO RPS.

g. The ROO RPS must upload the readings from the Instadose devices and record the
results in the Dose Record spread sheet.

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SOP03 - Identifying and Handling of NORM Contaminated Tubulars

Intent

The intent of this procedure is to describe the actions required to identify, handle, and dispose of
Naturally Occurring Radioactive Material (NORM) contaminated tubulars and other equipment removed
from production wells. The scope of the procedure applies to all production tubulars and other
equipment that have been exposed to reservoir fluids in the Rumaila oilfield that is managed by the
Rumaila Operating Organisation. Note - This SOP is for production tubulars and not work or injection
strings.

Roles and Responsibilities

1. NORM Competent Person (personnel who have successfully completed the ROO level 2 basic
user training) - Carries out NORM measurements and implements NORM control measures as
detailed below.

2. Radiation Protection Supervisors (RPS) (personnel who have successfully completed an RPS
training course) – Provides guidance on working with NORM if required by NORM Competent
Persons and carries out additional risk assessments if unusually high NORM readings are
observed (see section 2b below) (e-mail: [email protected]).

NOTE: ESPs or other contractors should follw the ROO procedure in respect of
readings, NORM kit type or other associated prosepects.

Procedure

1. Preparation for work where NORM contamination may be present

Before starting a job where there is a potential for NORM contamination, it is important that the
workforce and worksite are prepared. It is essential that all personnel are briefed on the hazards
associated with NORM during any toolbox talks.

The following equipment must be available before work starts:

a. Contamination monitor (T407 c/w SA-50 probe)

b. Dose rate monitor (T202)

The following equipment must be available in the event that NORM contamination is identified:

a. ‘NORM Contaminated’ tags and tape (use duct tape if not available)

b. ‘NORM Supervised Area’ signs

c. Barriers (scaffold or chains)

d. P3-rated respirator (e.g. 3M 8835)

e. Rubber/PVC safety boots and chemical resistant gloves

f. Tyvek disposable coveralls

g. Shallow water bath for cleaning contaminated boots and other PPE

h. Heavy duty (1000-gauge 250 micron) polythene sheeting in case of external

contamination

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i. Heavy duty (1000-gauge 250 micron) polythene bags (for sealing tubular ends where
end caps are not available)

j. Cable ties to attach tags.

2. Monitoring for NORM contaminated tubulars and well control equipment

a. The identification point for NORM contamination is 3 cps abg (counts per second above
background), i.e. any item with readings equal to or greater than 3cps abg is considered
NORM contaminated

b. If a reading of 200cps abg or more is measured, then a dose rate measurement must
be made roughly 10cm from the contaminated surfaces using a T202 monitor. If this
reading is 7.5 µSv/h or more, the ROO RPS must be contacted to carry out an
additional risk assessment before work continues. Below 7.5 µSv/h, no time limitation
is required.

c. Form NORM01B – Record of Work Involving NORM (Workover) must be completed

for every job requiring a NORM check.

d. Before starting the measurement, establish the background radiation level using the
T407 with SA-50 probe at the site.

e. The joints and equipment must be checked for NORM contamination as the string is
being pulled.

f. The first 10 joints must be tested; if these are all clear of NORM then the testing may
be to every tenth joint until all tubulars are pulled then test the last 10 joints that are
pulled.

g. All well equipment pulled with the string must be tested at all open ends; this includes
the Christmas tree and any chokes or valves.

h. If contamination is found work must be stopped and the worksite secured, the Site
Team Leader must then be contacted, and all NORM procedures put in place before
work continues (see below).

i. Note that contamination may be found at any point in a string and so monitoring must
be carried out for the full length of the string; zero readings in the first few tubulars are
not an indication of a NORM free string.

3. Handling of NORM Contaminated Tubulars and Well Control Equipment

a. Tyvek coveralls, a P3-rated mask (e.g. 3M 8835), Rubber/PVC safety boots and
chemical resistant gloves must be worn prior to any NORM handling.

b. The work area and any NORM laydown areas must be demarcated as NORM
Supervised Areas with warning signs in English and Arabic.

c. The Supervised Areas should only have one entry/exit point and personnel entering
the area must be kept to a safe minimum.

d. Personnel must be signed in and out of the area and checked for contamination as
they leave.

e. Contaminated boots are to be cleaned in a shallow bath and contaminated coveralls

and gloves should be wiped clean if possible.

f. Any PPE which remains contaminated should be bagged, placed in a sealed container
and labelled NORM waste. Contact Rumaila Waste Centre Co-ordinator
([email protected])for guidance on where to dispose of this container.

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g. If water from the ‘boot’ bath contains NORM at the end of the job, then it may be put
back down the well.

h. All NORM contaminated tubulars must have end caps inserted to prevent any loose
scale falling out; if any scale falls out prior to end caps being inserted the scale should
be placed back inside the tubular. If end caps are not available, the ends should be
sealed with heavy duty polythene bags and yellow/black ‘NORM Contaminated’ tape
(use duct tape if not available).

i. Yellow/black ‘NORM Contaminated’ tags must be attached to both ends of each

contaminated joint and the details of the job must be written on the tags.

j. Yellow/black ‘NORM Contaminated’ tape should be wrapped around the ends of the
contaminated tubulars to help identification.

k. After all NORM tubulars have been secured, all pipe racks and catwalks shall be
checked for NORM.

l. NORM contaminated tubulars must be temporarily stored in a dedicated NORM

laydown area on-site. Non-contaminated items must not be stored in this area. The
temporary laydown area for contaminated tubulars must have floor coverings (e.g.
plastic sheeting) between the first layer of joints and the bare ground if there is a risk
of ground contamination.

m. Contact the Rumaila Waste Centre Co-ordinator ([email protected])at

least 2 working days before transport, to allow arrangements to be made for receipt of
contaminated tubulars. Transport to the Rumaila Waste Centre. Do not transport
NORM contaminated tubulars on the same truck as non-contaminated.

n. Note - Occasionally a string may have joints that give readings on the external surface
with the SA-50 probe. This is either due to external contamination or gamma radiation
penetrating the steel from the inside. The SA-49 probe must be used to confirm
external contamination.

o. If there are elevated readings on the external surface of a joint using the SA-49 then it
is externally contaminated and must be wrapped in heavy duty polythene and taped
with yellow/black ‘NORM Contaminated’ tape (use duct tape if not available). Tags
should be attached to both ends and be clearly visible.

p. If the workover team is unsure about the radiation safety of the job at any point the
ROO RPS must be contacted for guidance.

4. Handling of Non-Contaminated Tubulars

a. All non-contaminated tubulars must be temporarily stored in a laydown area on-site,
separate from contaminated items. Do not mix contaminated with non-contaminated.

b. Complete the transport manifest showing that the tubulars have been tested for NORM
and are non-contaminated.

c. Transport to pipe yard with accompanying manifest.

5. Reinstatement of Well Equipment

If a string is pulled from the well temporarily such that it will be reinstated without leaving the rig site,
then several of the steps in section 3 may be relaxed. Steps 3a to 3h must still be followed in the event
of contamination being identified and contaminated tubulars must be segregated from non-
contaminated tubulars. It is not necessary to label each tubular if they are going back down the well.

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6. Inability to comply with procedure requirements
Under exceptional circumstances it may not be possible to comply with all the requirements of this
procedure. If you are unable to comply with the requirements of this procedure a formal risk
assessment, including defining and documenting the risk reduction measures that are to be applied,
must be completed. After the risk assessment has been completed (led by the Industrial Hygiene RPS)
it shall be approved by the Wells Workover Manager prior to any work being completed.

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SOP for Level 2 Competent Person – Identifying and Handling NORM Contaminated Tubulars
a. Workover Rig site pulling tubulars with wet surfaces

b. NORM measurement performed by NORM competent user using T407 with SA-50 probe. Calibrated
meter provided by HSE

c. Establish background reading 2 meters from tubulars inside the provided short section of clean pipe

d. First ten joints to be checked on the pipe rack by inserting SA-50 probe into both pin and box ends (must
be past the thread in the box end) and if clear test every tenth tubular

Contaminated

(≥3cps above background)

Yes No
Yes

High
Readings Yes

(≥200cps
above
background
)
High Dose Rate a. Rack all tubulars
No
Yes (≥7.5µSv/h
No above
b. Send copy of Form
Yes background) NORM01B to the
Senior RPS
Yes
Contact the ROO RPS to carry out
further risk assessment before
work continues. Additional
restrictions may apply.

• Label all contaminated tubulars as NORM

contaminated segregate from non-contaminated

• Notify the Rumaila Waste Centre Coordinator Send to Pipe Yard with
([email protected]) 2 working copy of Form NORM01B
days in advance of planned drop off

• Send copy of Form NORM01B to the Senior

RPS ([email protected])

Send to RWC with copy

of Form NORM01B

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SOP04 – Handling of Potentially NORM Contaminated Coiled Tubing

Intent

The intent of this procedure is to describe the actions required to identify, handle and clean Naturally
Occurring Radioactive Material (NORM) contaminated coiled tubing. The scope of the procedure
applies to all coiled tubing work scopes on production wells in the Rumaila oilfield that are managed by
the Rumaila Operating Organisation.

Roles and Responsibilities

1. NORM competent person (personnel who have successfully completed the ROO level 2 basic
user training) - Carries out initial site NORM measurements as detailed below.

2. Radiation Protection Supervisors (RPS) (personnel who have successfully completed an RPS
training course) – Control all work where NORM contamination has been determined (e-mail
[email protected]).

Procedure

1. Preparation for Work Where NORM Contamination May Be Present

Before starting a job where there is a potential for NORM contamination, it is important that the
workforce and worksite are prepared. It is essential that all personnel are briefed on the hazards
associated with NORM during any toolbox talks.

The following equipment must be available before work starts:

a. ‘NORM Contaminated’ tags and tape (use duct tape if not available)

b. ‘NORM Supervised Area’ signs

c. Barriers (scaffold or chains)

d. Contamination monitor (T407 c/w SA-50 and SA-49 probes)

e. Dose rate monitor (T202)

f. P3-rated respirator (e.g. 3M 8835)

g. Rubber/PVC safety boots and chemical resistant gloves

h. Tyvek disposable coveralls

i. Shallow water bath for cleaning contaminated boots and other PPE

j. Heavy duty (1000-gauge 250 micron) polythene sheeting in case of external

contamination

k. Heavy duty (1000-gauge 250 micron) polythene bags (for sealing tubular ends where
end caps are not available)

l. Cable ties to attach tags.

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2. Monitoring for NORM Contamination on Coiled Tubing
a. The identification point for NORM contamination is 3 cps (counts per second) above
background, i.e. any item with readings equal to or greater than 3cps above
background is considered NORM contaminated

b. If a reading of 200cps or more above background is measured, then a dose rate

measurement must be made roughly 10cm from the contaminated surface using a
T202 monitor. If this reading is 7.5µSv/h or more, the ROO RPS must be contacted to
carry out an additional risk assessment before work continues. Below 7.5µSv/h, no
time limitation is required.

c. Form NORM01B – Record of Work Involving NORM (Workover) must be completed

for every job requiring a NORM check.

d. Before starting the measurement, establish the background radiation level using the
T407 with SA-50 probe at the site.

e. The coiled tubing must be checked for NORM contamination as it is being pulled.

f. The tubing should be monitored continuously for the first 100ft with a suitable monitor,
e.g. T407 with SA-50 probe, as it is being pulled, keeping the probe at right angles and
as close to the tubing as possible.

g. If no contamination is found in the first 100ft then checks only need to be made at 100ft
intervals and on any visible deposits.

h. If contamination is found work must be stopped and the worksite secured, the Site
Team Leader must then be contacted, and all NORM procedures put in place before
work continues (see below).

i. Note that contamination may be found at any point and so the monitoring protocol must
be adhered to for the full length of coiled tubing.

3. Handling of NORM Contaminated Coiled Tubing

a. Tyvek coveralls, a P3-rated mask (e.g. 3M 8835), Rubber/PVC safety boots and
chemical resistant gloves must be worn prior to any NORM handling.

b. The work area must be demarcated as a NORM Supervised Area with warning signs
in English and Arabic.

c. The Supervised Area should only have one entry/exit point and personnel entering the
area must be kept to a safe minimum.

d. Personnel must be signed in and out of the area and checked for contamination as
they leave.

e. Attempts should be made to remove the contamination from the coiled tubing using
rags; these must then be placed into heavy duty plastic bags and sealed with NORM
tape and tags.

f. If it is not possible to clean using rags, then the ROO RPS must be contacted
([email protected]). More rigorous cleaning methods may be required
any these must be performed in accordance with NORM SOP09.

g. Contaminated boots are to be cleaned in a shallow bath and contaminated coveralls

and gloves should be wiped clean if possible.

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h. Any PPE which remains contaminated should be bagged, placed in a sealed container
and labelled NORM waste. Contact Rumaila Waste Centre Co-ordinator
([email protected]) for guidance on where to dispose of this container.

i. If water from the ‘boot’ bath contains NORM at the end of the job, then it must be
containerised and labelled as NORM contaminated. Contact ROO RPS
([email protected]) for guidance on where to dispose of this container.

4. Decontaminating and Reinstating the Worksite

a. At the end of operation all workers must be checked for contamination on their PPE,
particularly the soles of boots.

b. If possible, all clothing, materials and equipment used in work with NORM should be
decontaminated by washing or wiping down and kept for reuse or disposed of as non-
radioactive waste. If this is not possible contaminated clothing, materials and
equipment should be stored in sealed labelled container and sent for interim storage at
the Rumaila Waste Centre (RWC) with guidance from Rumaila Waste Centre Co-
ordinator ([email protected])

5. Inability to comply with procedure requirements.

Under exceptional circumstances it may not be possible to comply with all the requirements of
this procedure. If you are unable to comply with the requirements of this procedure a formal
risk assessment, including defining and documenting the risk reduction measures that are to
be applied, must be completed. After the risk assessment has been completed (led by the
RPS) it shall be approved by the Wells Workover Manager prior to any work being completed.

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SOP05 - Handling of Potentially NORM Contaminated Downhole Tools (Including Nuclear
Logging Tools)

Intent

All items of equipment which have been down-hole and exposed to production fluids could be
contaminated with NORM. It is essential that these items are monitored as they are pulled from the
well and dealt with accordingly.

Several downhole tools incorporate small radioactive sources or neutron generators which are used for
measurement and calibration of the tool. This can make them more difficult to monitor than other
equipment. Monitoring on the outside of a tool containing a radioactive source will produce a high count
rate. Tools incorporating neutron sources or neutron generators are capable of creating a localised
area of activity in the tool during extended operation. This localised activity decays away quite rapidly
over several hours but can give high count rates on a contamination monitor if measured just after
pulling from the well.

This SOP aims to outline the approach to monitoring these tools for NORM contamination.

Roles and Responsibilities

1. NORM competent person (personnel who have successfully completed the ROO level 2 basic
user training) - Carries out site NORM measurements as required.

2. Radiation Protection supervisors (RPS) (personnel who have successfully completed an RPS
training course) – Control all work where NORM contamination has been determined.

Procedure

1. Preparation for work where NORM contamination may be present

Before starting a job where there is a potential for NORM contamination, it is important that the
workforce and worksite are prepared. It is essential that all personnel are briefed on the hazards
associated with NORM during any toolbox talks.

The following equipment must be available before work starts:

a. ‘NORM Contaminated’ tags and tape (use duct tape if not available)

b. ‘NORM Supervised Area’ signs

c. Barriers (scaffold or chains)

d. Contamination monitor (T407 c/w SA-50 and SA-49 probes)

e. Dose rate monitor (T202)

f. P3-rated respirator (e.g. 3M 8835)

g. Rubber/PVC safety boots and chemical resistant gloves

h. Tyvek disposable coveralls

i. Shallow water bath for cleaning contaminated boots and other PPE

j. Heavy duty (1000-gauge 250 micron) polythene sheeting in case of external

contamination

k. Cable ties to attach tags.

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2. Monitoring for NORM Contamination

a. The identification point for NORM is 3 cps (counts per second) above background, i.e.
any item with readings equal to or greater than 3cps above background is considered
NORM contaminated

b. If a reading of 200cps or more above background is measured, then a dose rate

measurement must be made roughly 10cm from the contaminated surface using a
T202 monitor. If this reading is 7.5µSv/h or more, the ROO RPS must be contacted to
carry out an additional risk assessment before work continues. Below 7.5µSv/h, no
time limitation is required.

c. Form NORM01B – Record of Work Involving NORM (Workover) must be completed

for every job requiring a NORM check.

d. Before starting the measurement, establish the background radiation level using the
T407 with SA-50 probe at the site

e. Any equipment pulled from the well must be tested where there are visible deposits
(please see below for nuclear logging tools)

f. Any debris removed from the well must also be tested

g. If contamination is found work must be stopped and the worksite secured, the and Site
Team Leader must then be contacted, and all NORM procedures put in place before
work continues (see below).

3. Handling of NORM Contaminated Tools

a. Tyvek coveralls, a P3-rated mask (e.g. 3M 8835), Rubber/PVC safety boots and
chemical resistant gloves must be worn prior to any NORM handling.

b. The work area and any NORM laydown areas must be demarcated as NORM
Supervised Areas with warning signs in English and Arabic.

c. The Supervised Areas should only have one entry/exit point and personnel entering
the area must be kept to a safe minimum.

d. Personnel must be signed in and out of the area and checked for contamination as
they leave.

e. Contaminated boots are to be cleaned in a shallow bath and contaminated coveralls

and gloves should be wiped clean if possible.

f. Any PPE which remains contaminated should be bagged, placed in a sealed container
and labelled NORM waste. Contact Rumaila Waste Centre Co-ordinator
([email protected])for guidance on where to dispose of this container.

g. If water from the ‘boot’ bath contains NORM at the end of the job, then it may be put
back down the well.

h. Where possible the contamination should be removed from the item by light hosing or
wiping down; please note that if hosing equipment down the effluent must be captured
for disposal.

i. Any solid material removed must be bagged, placed in a sealed container and labelled
NORM waste along with any rags used to wipe items down. Contact Rumaila Waste
Centre Co-ordinator ([email protected])for guidance on where to
dispose of this container.

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j. Any liquids captured from hosing equipment down can be disposed of down the well.

k. If it is not possible to remove the contamination with these light cleaning methods the
equipment must be wrapped in heavy duty polythene sheeting and marked up as
NORM contaminated until more rigorous cleaning can be performed as per SOP09.

l. Yellow/black ‘NORM Contaminated’ tags must be attached to the item and the details
of the job must be written on the tags.

m. Yellow/black ‘NORM Contaminated’ tape should be used to seal the polythene

wrapping.

n. NORM contaminated items must be temporarily stored in a dedicated NORM laydown

area on-site. Non-contaminated items must not be stored in this area.

o. Arrangements must be made for more rigorous cleaning to be carried out under the
supervision of a qualified engineer.

4. Dealing with Tools Which Incorporate Sealed Sources

If a tool incorporates a sealed source, then it will produce a high count rate when monitored
with a contamination monitor. To assist in determining whether or not a tool is NORM
contaminated a measurement should be made before the tool goes down hole to determine a
‘background’. Tools incorporating a neutron-emitting source may also become activated by
that source, see below for more details. Contact the RPA if there is any uncertainty.

5. Dealing with Tools Which May Have Been Activated

If it is felt that a tool could be activated during operations due to the use of a neutron emitting
device (e.g. neutron generator, Cf-252 source or Am-241/Be source) then on retrieval the tool
should be isolated for several hours prior to carrying out a NORM check. If activity is found,
then the tool should be left for a further period of time to see if the count level decreases any
further. If activity remains, then a decision must be made as to whether it is contaminated or
not. If there is any uncertainty, then contact the RPA.

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SOP06 – Milling of NORM Scale and Handling NORM Contaminated Fluids

Intent

Experience on some production wells has indicated that NORM scale can build up in the liner below
the packer. This necessitates a clean-out operation to remove this scale by milling. Small scale particles
are circulated out with the brine; larger particles are caught in a junk-sub. Other operations can also
require the filtering of fluids or muds which have been circulated down hole and could potentially be
contaminated. Occasionally there may be a build-up of NORM contaminated wax- or tar-like material
in a well which may require circulation of solvents in order to clear it. This SOP outlines the generic
steps to take in order to control the radiations risks to both people and the environment in these
instances; however, the RPA should be consulted at the planning stage for any non-routine jobs of this
type.

Roles and responsibilities

1. NORM competent person (personnel who have successfully completed the ROO level 2 basic
user training) - carry out site radiation measurements as requested.

2. Radiation Protection Supervisors (personnel who have successfully completed an RPS training
course) - Control all work where NORM contamination has been determined.

Procedure

1. Preparation for Work

Before starting a job where there is a potential for NORM contamination, it is important that the
workforce and worksite are prepared. It is essential that all personnel are briefed on the hazards
associated with NORM during any toolbox talks.

The following equipment should be available before work starts:

a. ‘NORM Contaminated’ tape and tags

b. ‘NORM Supervised Area’ signs

c. Barriers (scaffold or chains)

d. Contamination monitor (T407 c/w SA-50 probe)

e. P3-rated respirator (e.g. 3M 8835)

f. 3M 6000 Series with 6055 cartridges if dealing with organic vapours

g. Rubber/PVC boots and gloves

h. Tyvek disposable coveralls

i. Shallow water bath for cleaning contaminated boots and other PPE

j. Heavy duty (1000-gauge 250 micron) polythene sheeting

If fluid holding pits are to be used, they must be lined adequately to prevent ground contamination. If
tanks are to be used, then it must be anticipated that in the event of NORM contamination being
identified in the fluids these tanks may require decontamination.

Some muds / brines have naturally radioactive additives in them and so to avoid false positives it is
recommended that a known volume (roughly 500ml) is sampled prior to use. A reading must be taken
of this sample using the contamination monitor to determine the baseline. Using the 3cps rule below
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this means that if a known volume of unused mud presents a reading of 5cps above the ambient
background, the same volume would need to give a reading of 8cps or more above the ambient
background after use to indicate NORM contamination.

If fluids are to be filtered, then the type of filter used should be easily decontaminable or disposable as
the captured solids may be NORM contaminated.

2. Identification and early management of identified NORM

a. Before starting the measurement, establish the background radiation level using the
T407 with SA 50 probe; if a reading has already been taken of unused fluids then this
should be taken as the background (see previous section).

b. Where possible measurements should be taken at the shakers to allow for early
identification of NORM.

c. Take a representative sample of the resultant fluids and monitor this sample using the
T407 with SA 50 probe and record results on form NORM01.

d. The identification point for NORM contamination is 3cps abg (counts per second above
background) or more, i.e. a reading greater than or equal to 3cps abg is considered
NORM contaminated.

e. If filtering has been carried out, then the filters must be checked for NORM
contamination.

f. If there are any residual solids when the fluids have been drained from the pit / tank,
then these must also be checked for NORM contamination. Note: fluids should be
drained from the top to avoid agitating settled solids.

g. Once the fluids and residual solids have been removed the tank or pit liner must be
checked for NORM contamination.

3. Working with NORM Contaminated Material

h. If NORM contamination is identified, then operations involving the handling of this
material must be conducted within a NORM Supervised Area and a ROO RPS must
be notified.

i. To set up the Supervised Area the barrier around the worksite site should have signs
posted stating that it is a Supervised Area. These signs must also have the word
‘Radiation’ on them and the radiation trefoil. Signage must be in English and Arabic.
A well-controlled entry point to the Supervised Area should be set up with adequate
space for a decontamination zone for personnel to don and remove their PPE. Ideally
this area should have plastic sheeting on the floor to control contamination spread.

j. Form NORM01 – Record of Work Involving NORM must be used to record the entry
and exit of personnel as well as all contamination checks.

k. If readings in excess of 200cps are measured, then a dose rate measurement must be
made using the T202; if a dose rate greater than 3µSv/h the ROO Industrial Hygienist
must be contacted to prepare a risk assessment and inform the workforce of the time
constraints.

l. Tyvek coveralls, P3 (or N100) mask, Rubber safety boots and chemical resistant gloves
must be worn inside the NORM Supervised Area.

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m. If the risk assessment identifies the requirement for a higher specification of RPE then
this must be worn, for example if working with solvents then a respirator rated for use
with organic vapours must be used (3M 6000 Series with 6055 cartridge).

n. Personnel must be checked for contamination as they leave the area using the T407
with SA-50 probe; the threshold for NORM contamination is 3cps above background.

o. Contaminated boots are to be cleaned in a shallow bath in the decontamination area

and contaminated Tyvek suits and gloves should be wiped clean if possible and the
contaminated equipment should be cleaned.

p. Any PPE which remains contaminated should be bagged, placed in a sealed container
and labelled NORM waste. Contact Rumaila Waste Centre Co-ordinator
([email protected])for guidance on where to dispose of the container.

q. If water from the ‘boot’ bath contains NORM at the end of the job then it may be put
back down the well; if this is not possible then contact the Rumaila Waste Centre Co-
ordinator ([email protected])for guidance.

r. No eating, drinking or chewing gum inside the NORM Supervised Area.

4. Decontaminating and Reinstating the Worksite

a. At the end of operation all workers must be checked for contamination on their PPE,
particularly gloves and the soles of boots.

b. If possible, all clothing, materials and equipment used in work with NORM should be
decontaminated by washing or wiping down and kept for reuse or disposed of as non-
radioactive waste. If this is not possible contaminated clothing, materials and
equipment should be stored in sealed labelled containers and the Rumaila Waste
Centre Co-ordinator ([email protected])should be notified 2 working
days in advance to arrange disposed / storage.

5. Management of Resultant NORM Waste

There several potential NORM waste streams from this work:

1. NORM contaminated liquids

The ROO Environmental team will provide guidance for disposal of NORM contaminated
liquids; they must be contacted 2 working days in advance of any movement of NORM waste.

2. NORM sludge / scale removed manually from the pit / tank and decanted into lined drums
These drums of waste must be marked for traceability. The Rumaila Waste Centre Co-ordinator
([email protected]) will provide guidance for interim storage of NORM
contaminated wastes; they must be contacted 2 working days in advance of any movement of
NORM waste.

3. NORM contaminated filters

If filters can be cleaned on site, then this should be done following SOP09 as appropriate. If it
is not possible to decontaminate them or the filter material is disposable, they should be
wrapped / contained and marked up as NORM contaminated. The Rumaila Waste Centre Co-
ordinator ([email protected]) will provide guidance for interim storage of NORM
contaminated wastes; they must be contacted 2 working days in advance of any movement of
NORM waste.
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4. NORM contaminated PPE and rags
Bags / containers of NORM contaminated PPE must be marked for traceability. The Rumaila
Waste Centre Co-ordinator ([email protected]) will provide guidance for interim
storage of NORM contaminated wastes; they must be contacted 24 hours in advance of any
movement of NORM waste.

5. NORM contaminated tools and equipment

NORM contaminated tools and equipment should be wiped down if possible and the rags
placed into bags/containers as in iv above. If this is not possible then contaminated equipment
should be wrapped / contained. The Rumaila Waste Centre Co-ordinator
([email protected]) will provide guidance for interim storage of NORM
contaminated wastes; they must be contacted 2 working days in advance of any movement of
NORM waste.

If tanks were used to store the fluids prior to offload then these may be contaminated, if so then SOP02
should be followed for decontamination.

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SOP07 – NORM Sampling Methodology and Consignment

Intent

This procedure describes the general requirements for taking samples of NORM contaminated material
and transporting these samples for transport within the Rumaila concession between ROO operated
sites. Please note: this procedure does not enable samples to be sent out with Rumaila; if this is
required then contact the ROO RPA.

Roles and Responsibilities

1. Radiation Protection Supervisor (personnel who have successfully completed an RPS training
course) –The RPS will carry out this work in accordance with this procedure.

Procedure

1. Sampling Methodology
The PPE worn during sampling must be commensurate with the related task (see relevant SOPs,
depending on the work being undertaken).

Samples must be placed into good quality (preferably UN approved) bottles and the sample should be
50g – 100g.

The sample must be representative; this can be achieved by taking small amounts of material from
several regions in the waste.

2. Packaging and Labelling

a. Secure the lid of each sample bottle tightly.

b. Mark each bottle with the sample details; job number, date sample was taken, site
reference and the word ‘Radioactive’.

c. Place the bottles into a new cardboard box that can withstand the routine transport
conditions. The box must be filled with sufficient packaging material to protect the
bottles during transport and absorb any leaks.

d. The external surface of the box must be checked with a dose rate monitor (e.g. T202)
to ensure that the dose rate is below 5µSv/h; if the dose rate is above this level then
the ROO RPA should be contacted for further advice.

e. The external surface of the box must be clearly and legibly marked with the name and
address of the consignor and consignee.

3. Transport Documentation

A transport document must be completed with the following information as a minimum:

a. Consignor and consignee

b. A description of the contents

c. Weight of the package

d. Number of packages

e. Emergency contact details

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SOP08 – Transportation of NORM Waste

Intent

Iraq is a member state of the International Atomic Energy Agency (IAEA) and therefore must observe
the recommendations of the IAEA. In lieu of proper legislation on the transportation of radioactive
material, the latest version of the IAEA Regulations for the Safe Transportation of Radioactive Material
must be used within ROO. This SOP describes how to transport NORM contaminated equipment and
material by road.

Roles and Responsibilities

1. Contractor NORM competent person (personnel who have successfully completed the ROO
level 2 basic user training) – This person will carry out the NORM cheking and label the items
to NORM contaminated or not and ensure that NORM contaminated equipment and material is
transported in accordance with this document. The NORM competent person will be involved
in that has resulted in the NORM waste / equipment, for example the well site leader if dealing
with tubulars.

2. Radiation Protection Supervisor (RPS) (personnel who have successfully completed an RPS
training course) – will provide additional support to the NORM competent person where
required (e-mail: [email protected]).

NORM Contaminated Equipment

NORM contaminated items must be suitably wrapped to prevent escape of NORM during transit, e.g.
open ends sealed with flange protectors, end caps or plastic sheeting (1000-gauge 250 micron), as
appropriate and these wrappings must be taped / tie-wrapped in place with yellow / black NORM tape
and tags. Where possible, at least two tags should be attached to each item. NORM tape must also
be wound around the item to clearly and easily identify it as NORM contaminated. If any loose scale
falls out of an item prior to sealing it must be inserted back into the item.

Items must be placed in fully sealable containers or units that can be covered; if this is not possible due
to the size of an item then it may be transported as unpackaged with the permission of the ROO RPS.

NORM contaminated equipment must be dispatched as SCO-I Radioactive Material - UN2913.

Each package must have labels affixed to two opposing sides with the following information:

a. Consignor and consignee

b. ‘UN2913’

c. Gross weight (if greater than 50kg)

Each package must also have the correct radiation hazard diamonds affixed to two opposing sides.
The contents must be marked as ‘Ra-226, Ra-228 and daughters (SCO-I)’ and the activity must be
marked as ‘<5MBq’. See below for information on selecting the correct hazard diamond.

CCUs containing these items must be labelled on all four sides with the same information.

NORM Sand and Sludge

The type of packaging used should be agreed with the receiving site and delivered to the work site
before work begins. The packages must be suitable for storing the waste safely at the site and must
comply with the transport regulations for the modes of transport being used. Note – solid waste should
not be placed in packages / containers designed for liquids e.g. tote tanks, and vice versa.

Excess water removal will be required once the waste is contained in the shipping package(s). A period
of settling will often be required to ensure that the remaining liquids are kept to a minimum before
shipping. This time lapse should be included in any planning.
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Each package must have labels affixed to two opposing sides with the following information:

a. Consignor and consignee

b. ‘UN2912’

c. Gross weight (if greater than 50kg)

Each package must also have the correct radiation hazard diamonds affixed to two opposing sides.
The contents must be marked as ‘LSA-I’ and the activity must be marked as ‘<10MBq’. See below for
information on selecting the correct hazard diamond.

CCUs containing these packages must be labelled on all four sides with the same information.

Hazard Diamonds and Placards

All vehicles carrying class 7 dangerous goods other than excepted packages must bear the generic
class 7 placard. Three placards must be used; one on each side of the vehicle and one at the rear of
the vehicle. In addition to these placards, orange plates must be affixed to the front and rear of the
vehicle.

The correct hazard diamond to use when labelling packages can be determined using the table below.
There are two factors to consider; the transport index and the surface dose rate. The transport index,
or TI, is determined by measuring the dose rate in µSv/h at 1m from the surface of the package and
dividing this by 10. The TI must be written on the hazard diamond if it is a yellow – II or III but is not
required for white – I as the TI must be 0 for these. If any package requires yellow – III hazard diamonds
the RPA must be contacted prior to consignment.

Classification Transport Index (TI) External Surface Dose Rate

White – I 0 < 5µSv/h

Yellow – II > 0, < 1 > 5µSv/h, < 500µSv/h

Yellow – III > 1, <10 > 500µSv/h, < 2000µSv/h

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SOP09 – Decontamination of NORM Contaminated Items on the Site

Intent

The most efficient option for cleaning pieces of NORM contaminated equipment from ROO-operated
sites is to clean them in the field. This standard operating procedure provides the basic guidelines for
this type of work. On-site decontamination is usually performed by dedicated trained cleaning
contractors following their own procedures. The area in which the cleaning work is taking place will be
designated as a Controlled Area.

Roles and Responsibilities

1. Specialist Contractors – These workers will carry out the cleaning work once the responsibility
for the Controlled Area has been handed over to their company.

2. Contractor’s Radiation Protection Supervisor (RPS) – This worker will ensure the correct
procedures are followed for all work inside the NORM Controlled Area.

3. ROO RPS (personnel who have successfully completed an appropriate RPS training course) –
The ROO RPS will oversee the preparation stage of the work until the responsibility is handed
over to the contractor and act as an interface between the contractor work party and ROO.

NOTE: These activities are not covered by the risk assessment in section 7.0 of this document and
must be risk assessed separately for radiation dose. Contractors carrying out this work must provide
their own risk assessment. If ROO personnel are to be involved in carrying out the work, then the ROO
RPA must be contacted at the planning stage.

Procedure

1. Preparation for Work

Before work begins the following points must be followed:

The ROO Senior RPS must be informed of the details of the job, including the decontamination
arrangements and the extent of the work to be carried out.

The area of work must be fully enclosed (e.g. decontamination container or habitat) and demarcated as
a Controlled Area with signs in English and Arabic.

A decontamination zone must be designated with one entry/exit point.

The ROO RPS and the contractor RPS must complete Form NORM03 – Checklist for Cleaning
Contractors Working with NORM (see Section 9.0 of ROO-ALL-HS-PRO-0109) together to identify any
issues.

The responsibility of the controlled area must be handed over from ROO to the contractor via Form
NORM04 – Responsibility for a Radiation Controlled Area (see Section 9.0 of ROO-ALL-HS-PRO-
0109).

Confirm that there is an appropriate disposal route or storage location for the NORM contaminated
material removed from the equipment.

Ensure there are the appropriate means to collect all solids and effluent that result from the cleaning
process.

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2. Segregation of Equipment and Material
Three separate storage areas should be set up next to the work area:

A holding area must be set up for NORM contaminated equipment that is waiting to be cleaned. The
equipment in this area must have all openings covered with heavy duty polythene and each item must
be suitably labelled as NORM contaminated. This area must be designated as a NORM Supervised
Area with signage in English and Arabic.

A waste storage area should be set up for all NORM contaminated material removed from equipment
during the cleaning process; this includes effluents. Again, this should be designated as a NORM
Supervised Area with signage in English and Arabic. Loose scale must be sealed in heavy-duty
polythene bags, placed into drums and marked as NORM contaminated. Effluent from the cleaning
process must be containerized and labelled. Rumaila Waste Centre Co-ordinator
([email protected]) should be notified 2 working days in advance so that
storage/disposal can be arranged.

A third storage area should be set up for equipment that has been cleaned and is no longer NORM
contaminated. This area does not require any special designation.

3. Clearance Instructions
After a piece of equipment has been cleaned it must be monitored for residual contamination.

The contractor’s procedures must give detailed step-by-step instructions on clearance testing. These
will require testing of all potentially contaminated surfaces when the surfaces are dry. For long pieces
of pipework being sent onshore as scrap, this may require cutting to make inside surfaces accessible.
For assemblies or complicated equipment this may require breakdown into component parts.

If pipework is cut or assemblies broken down, a numbering system must be used to allow traceability
of all items. The numbers must be marked on the parts and should correlate with the Clearance
Certificate provided by the contractor.

The contractor local rules will give precise clearance testing instructions, including guidance on access
to surfaces, spacing of test points, testing of seams, corners, pockets and irregularities.

The contractor will provide a Clearance Certificate acceptable to ROO certifying that the items have
been decontaminated to the required standard. The Clearance Certificate will be signed by the
contractor RPS on behalf of the Contractor Company. The Clearance Certificate will identify the items
that it covers.

NORM contaminated items to be reinstated on site need not be cleaned until entirely NORM free, so
long as it will not affect the performance of the system. The workers performing the reinstatement must
adhere to the ROO NORM controls described in SOP01.

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SOP10 – Working with NORM (Remediation Projects)

Intent

The intent of this procedure is to describe the actions required protect the Remediation Teams while
they are working in NORM contaminated areas. The scope of the procedure applies to all areas that
have been exposed to hydrocarbons and formation water.

Roles and responsibilities

NORM competent person (personnel who have successfully completed the ROO level 2 basic user
training) – Member of the Remediation Team that can carry out site radiation measurements as
requested.

Radiation Protection supervisors (personnel who have successfully completed an appropriate RPS
training course) - Carry out training for the Remediation Team, this will include awareness, use of the
appropriate meters and the requirements of this SOP

Procedure

1. Determination of NORM Contamination

Due to the vast quantities of potentially NORM contaminated material on the remediation sites it is
almost certain that a direct measurement inside the remediation area will result in a positive reading.
Initially each phase into which the remediation site is subdivided should have a rough walkover carried
out using the T407 c/w SA-50 probe to determine the uniformity of the readings. If the readings are
sporadic and non-uniform across relatively small areas, then the RPA should be consulted to discuss
the best way forward. If the readings are roughly uniform over significant areas, then each of these
areas within the phase should be sampled.

Representative samples should be obtained from each area within the remediation phase by mixing
small quantities from across the area into a sample bottle totalling approximately 100-200g of material.
Remember that soils and sludges are likely to have quite different levels of NORM contamination and
so should be sampled and measured separately where possible. Sample bottles should have screw
caps, and these must be fastened securely to prevent leakage.

In cases where excavation has already taken place without proper sampling taking place the resultant
stockpiles must be characterised. The sampling regime must be devised on a case-by-case basis
under the instruction of the RPA. In this situation contact the RPA immediately so characterisation can
be carried out in a timely fashion.

Once the samples have been obtained, they should be removed to a low background area (e.g. the site
offices) ensuring there is no leakage and the external surfaces of the bottles are clean. Choose an area
in which you will make your measurement and ensure the samples are an adequate distance from here
(at least 3m away). Take a background measurement in this area. Once the background has been
recorded each sample can be moved to this area individually to have its measurement taken; it is
recommended that the integrate function on the T407 is used for these measurements. If a sample
gives a reading of 3cps or more above background, then the source material should be treated as
NORM contaminated and the remainder of this SOP should be followed for that area. Repeat this
process for each sample.

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2. Preparation for Work in NORM Contaminated Areas

When NORM contamination is present all further work must be carried out in a radiation Supervised
Area (see section 3 of ROO-ALL-HS-PRO-0109). The following equipment should be available before
work commences:

NORM contaminated tags and tape

NORM Supervised area signs

Barriers (scaffold or chains)

Contamination Monitor (T407 c/w SA-50 probe)

Dose rate monitor (T202)

P3-rated respirator (e.g. 3M 8835)

Rubber safety boots or full-length waders

Chemical resistant gloves

Tyvek disposal coveralls

Shallow water bath for cleaning contaminated boots and other PPEHeavy duty (1000-gauge 250
micron) polythene bags for PPE disposal

Please note: In summer months it may be too hot to wear regular coveralls and Tyvek at the same time
due to the risk of heat stress. Under these circumstances Tyvek suits need not be worn and workers’
regular coveralls must remain on the site within a small dressing area at the entrance to the NORM
Supervised Area. Daily checks of contamination on coveralls will be carried out and washing facilities
must be available on site. Additionally, there will be a requirement for suitable drinking water facilities
to be made available during the summer. The current recommendation is that a foot pedal-operated
water fountain is brought to site and set up in a designated area near to the work area.

3. Working in NORM Contaminated Areas

To set up the Supervised Area the barrier around the worksite site should have signs posted stating
that it is a Supervised Area. These signs must also have the word ‘Radiation’ on them and the radiation
trefoil. Signage must be in English and Arabic. A well-controlled entry point to the Supervised Area
should be set up with adequate space for a decontamination zone for personnel to don and remove
their PPE. Ideally this area should have a habitat around it and plastic sheeting on the floor to control
contamination spread.

Form NORM01A – Record of Work Involving NORM must be used to record the entry and exit of
personnel as well as all contamination checks.

A dose rate measurement must be made using the T202 in each phase of the remediation area when
it is entered; if a dose rate greater than 3µSv/h the ROO Industrial Hygienist must be contacted to
prepare a risk assessment and inform the Remediation Team of the time constraints. It may be possible
to obtain dose rate information from previous UXO clearance work in the area.

Tyvek coveralls (see above for summer months), P3 (or N100) if this is not available then a P2 (or N95),
Rubber safety boots or full-length waders and chemical resistant gloves must be worn inside the NORM
contaminated area.

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Personnel must be checked for contamination as they leave the area using the T407 with SA-50 probe;
the threshold for NORM contamination is 3cps above background.

Contaminated boots are to be cleaned in a shallow bath in the decontamination area and contaminated
Tyvek suits and gloves should be wiped clean if possible and the contaminated equipment should be
cleaned. If Tyvek suits are not being used during summer months, then workers’ regular coveralls must
be quarantined and washed using the on-site facilities.

Any PPE which remains contaminated should be bagged, placed in a sealed container and labelled
NORM waste. Contact Rumaila Waste Centre Co-ordinator ([email protected])for
guidance on where to dispose of the container.

If water from boot bath or equipment cleaning contains NORM at the end of the job, then it may be put
back to the hydrocarbon contaminated area.

No eating, drinking or chewing gum inside the NORM Supervised Area. During the summer months
designated drinking areas will be set up close to the worksite.

4. Decontaminating and Reinstating the Worksite

At the end of operation all workers must be checked for contamination on their PPE, particularly the
soles of boots.

If possible, all clothing, materials and equipment used in work with NORM should be decontaminated
by washing or wiping down and kept for reuse or disposed of as non-radioactive waste. If this is not
possible contaminated clothing, materials and equipment should be stored in sealed labelled containers
and the ROO RPS (e-mail - [email protected]) should be notified 2 working days in
advance to arrange disposed / storage.

5. Removal of NORM Contaminated Sand, Sludge and Soil

When NORM contaminated material is being removed from a site it is important that it is transported
safely and responsibly. The following points must be adhered to when transporting NORM
contaminated material. If radiochemical analysis results are available for the material, then contact the
ROO RPA for further advice.

Where possible material should be contained in sealed skips or drums for transport. The skips must
be transported as per SOP08 and consideration must be given to cleaning / decontaminating the skips
after use.

If open-top trucks are used to transport NORM contaminated material it is essential that they are not
filled to maximum capacity. A tarpaulin must be secured over the top of the material to prevent spillage
during transit. Please note that it is not recommended to transport material in this way if it can be
avoided as there is no protection against spillage in the event of a road traffic incident. As with skips /
drums it is important that consideration is given to cleaning / decontamination of the trucks after use.

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SOP11 – Preparation of Ground Pads

Intent

The intent of this procedure is to describe the precautions that must be taken when preparing ground
pads on top of NORM contaminated soil. The purpose of these ground pads is to fix contamination in
place such that the internal hazard from NORM is eliminated.

Roles and responsibilities

NORM competent person (personnel who have successfully completed the ROO level 2 basic user
training) – Member of the team carrying out the work that can carry out site radiation measurements as
requested.

Radiation Protection supervisors (personnel who have successfully completed an RPS training course)
– Carry out training for the team carrying out the work, this will include awareness, use of the appropriate
meters and the requirements of this SOP.

Procedure

1. Determination of NORM Contamination

NORM contaminated ground should already have been identified on the degassing stations and
pumping stations; these areas will be highlighted on the hazard maps maintained by Industrial Hygiene.

All previously prepared ground pads will be marked on the Industrial Hygiene hazard maps and these
hazard maps must be updated to include new ground pads.

If dose rates in excess of 3µSv/h are present in the contaminated area, then Industrial Hygiene must
be contacted to determine how much soil must be excavated. The Industrial Hygiene RPS must contact
the RPA for further advice.

2. Preparation for Work in NORM Contaminated Areas

When NORM contamination is present, all of the following equipment should be available before work
commences:

a. NORM contaminated tags and tape

b. NORM Supervised area signs

c. Barriers (scaffold or chains)

d. Contamination Monitor (T407 c/w SA-50 probe)

e. Dose rate monitor (T202)

f. P3-rated respirator (e.g. 3M 8835)

g. Rubber safety boots

h. Chemical resistant gloves

i. Tyvek disposal coveralls

j. Shallow water bath for cleaning contaminated boots and other PPE

k. Heavy duty (1000-gauge 250 micron) polythene bags for PPE disposal

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3. Working in NORM Contaminated Areas

a. To set up the Supervised Area the barrier around the worksite site should have signs posted
stating that it is a Supervised Area. These signs must also have the word ‘Radiation’ on them and the
radiation trefoil. Signage must be in English and Arabic. A well-controlled entry point to the Supervised
Area should be set up with adequate space for a decontamination zone for personnel to don and remove
their PPE. Ideally this area should have a habitat around it and plastic sheeting on the floor to control
contamination spread.

b. Tyvek coveralls, P3 (or N100) respirators, if this is not available then P2 (or N95), Rubber safety
boots and chemical resistant gloves must be worn inside the NORM contaminated area.

c. Personnel must be checked for contamination as they leave the area using the T407 with SA-
50 probe; the threshold for NORM contamination is 3cps above background.

d. Contaminated boots are to be cleaned in a shallow bath in the decontamination area and
contaminated Tyvek suits and gloves should be wiped clean if possible and the contaminated
equipment should be cleaned. If Tyvek suits are not being used during summer months, then workers’
regular coveralls must be quarantined and washed using the on-site facilities.

e. Any PPE which remains contaminated should be bagged, placed in a sealed container and
labelled NORM waste. Contact Rumaila Waste Centre Co-ordinator
([email protected])for guidance on where to dispose of the container.

f. If water from boot bath or equipment cleaning contains NORM at the end of the job then the
Rumaila Waste Centre Co-ordinator ([email protected]) must be contacted for disposal
options.

g. No eating, drinking or chewing gum inside the NORM Supervised Area.

4. Preparation of Ground Pads

The purpose of preparing ground pads from a radiological point of view is to immobilise contamination
such that it cannot be ingested or inhaled by personnel. In order to do this, there must be a layer of
non-contaminated material (e.g. soil or concrete) placed on top of the contaminated ground with a
membrane between the contaminated and non-contaminated material. The membrane must prevent
solids from passing through it, but water must be able to pass through.

If the dose rate due to contaminated ground is greater than 3µSv/h, then consideration must be given
to removing some soil prior to installing the ground pad. The RPA should be contacted in this situation.

These steps must be followed:

Identify the extent of the ground pad and set up the Supervised Area as per section 3 above.

Wet the ground to minimise the generation of airborne dusts.

Remove soil if necessary (note that in many cases soil removal will not be necessary).

Compact the wet ground.

Install the membrane across the extent of the area.

Place clean soil OR install concrete pad.

Inform Industrial Hygiene when work is complete.

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5. Removal of NORM Contaminated Sand, Sludge and Soil

If NORM contaminated material is being removed from an area it is important that it is stored properly.
The material should be decanted into clip top drums lined with heavy duty plastic bags. The drums
must be marked with the job details for traceability and the Rumaila Waste Centre Co-ordinator
([email protected])must then be contacted to determine the disposal route.

6. Decontaminating and Reinstating the Worksite

a. At the end of operation all workers must be checked for contamination on their PPE,
particularly the soles of boots.

b. If possible, all clothing, materials and equipment used in work with NORM should be
decontaminated by washing or wiping down and kept for reuse or disposed of as non-
radioactive waste. If this is not possible contaminated clothing, materials and
equipment should be stored in sealed labelled containers and disposed of as NORM
waste by an agreed disposal route, with guidance from the Rumaila Waste Centre Co-
ordinator ([email protected]).

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SOP12 – Instructions for UXO Teams Working in NORM Contaminated Areas

Intent

The intent of this procedure is to describe the actions required to protect the UXO Teams while they
are working in NORM contaminated areas. The scope of the procedure applies to all areas that have
been exposed to hydrocarbons and formation (produced) water.

Roles and responsibilities

1. NORM competent person (personnel who have successfully completed the ROO level 2 basic
user training) – This will be the Arabian Gulf team leader on the site whose responsibility is to
carry out site radiation measurements as requested.

2. Radiation Protection Supervisors (personnel who have successfully completed an RPS training
course) – Carry out training for the UXO team; this will include awareness, use of the
appropriate meters and the requirements of this SOP.

Procedure

1. Determination of NORM Contamination

All areas requiring UXO clearance that have been exposed to significant amounts of
hydrocarbons or formation (produced) water will be assumed to be NORM contaminated. This
will include oil remediation sites, produced water lagoons etc. Areas in which there is NORM
contamination must be designated as Supervised Areas (see section 3 of ROO-ALL-HS-PRO-
0109); see below for instructions on how to set up a Supervised Area.

In areas where there has been no exposure to hydrocarbons or formation water then the
remaining steps of this procedure may be ignored.

2. Preparation for Work in NORM Contaminated Areas

If NORM contamination is present, all of the following equipment should be available before work
commences (contact ROO HSE to arrange supply):

a. NORM contaminated tags and tape

b. NORM Supervised area signs

c. Barriers (scaffold, chains, rope or tape)

d. Contamination Monitor (T407 c/w SA-50 probe)

e. Dose rate monitor (T202)

f. P3-rated respirator (e.g. 3M 8835)

g. Rubber safety boots or full-length waders

h. Gloves

i. Tyvek disposal coveralls – see note below for summer months

j. Shallow water bath for cleaning contaminated boots and other PPE

k. Heavy duty (1000-gauge 250 micron) polythene bags for PPE disposal

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Please note: In summer months it may be too hot to wear regular coveralls and Tyvek at the same time
due to the risk of heat stress. Under these circumstances Tyvek suits need not be worn and the workers’
regular coveralls must remain on the site within a small dressing area at the entrance to the NORM
Supervised Area. Daily checks of contamination on coveralls will be carried out and washing facilities
should be made available on site during the summer where possible. On some of the more remote
sites this will not be possible, and the RPA should be contacted to discuss the arrangements.

3. Working in NORM Contaminated Areas

a. To set up the Supervised Area the barrier around the worksite site should have signs
posted stating that it is a Supervised Area. These signs must also have the word
‘Radiation’ on them and the radiation trefoil. Signage must be in English and Arabic.
A well-controlled entry point to the Supervised Area should be set up with adequate
space for a decontamination zone for personnel to don and remove their PPE. Ideally
this area should have a habitat around it and plastic sheeting on the floor to control
contamination spread.

b. Form NORM01A – Record of Work Involving NORM must be used to record the entry
and exit of personnel as well as all contamination checks.

c. A dose rate measurement must be made using the T202 in each lot into which the UXO
clearance area is divided prior to continuing work; if a dose rate measurement greater
than 3µSv/h is measured then the ROO Industrial Hygienist must be contacted to
prepare a risk assessment and inform the UXO team of the time constraints.

d. Tyvek coveralls, P3 (or N100) respirators, if this is not available then P2 (or N95),
Rubber safety boots or full-length waders and gloves must be worn inside the NORM
contaminated area. Please see note above regarding PPE in summer.

e. Personnel must be checked for contamination as they leave the area using the T407
with SA-50 probe; the threshold for NORM contamination is 3cps above background.
Please contact the ROO Industrial Hygienist if there are difficulties ensuring these
checks are carried out.

f. Contaminated boots are to be cleaned in a shallow bath in the decontamination area

and contaminated Tyvek suits and gloves should be wiped clean if possible and the
contaminated equipment should be cleaned. If Tyvek suits are not being used during
summer months, then workers’ regular coveralls must be quarantined and washed
using the on-site facilities.

g. Any PPE which remains contaminated should be bagged, placed in a sealed container
and labelled NORM waste. Contact Rumaila Waste Centre Co-ordinator
([email protected])for guidance on where to dispose of the container.

h. If water from boot bath or equipment cleaning contains NORM at the end of the job
then the ROO Rumaila Waste Centre Co-ordinator ([email protected])
must be contacted for disposal options.

i. No eating, drinking or chewing gum inside the NORM Supervised Area.

4. Removal of Contaminated Scrap from the Worksite

It will often be necessary to remove scrap metal from the worksite to prevent interference with
UXO detection equipment. If possible the scrap metal should be moved to an area within the
NORM Supervised Area and the Rumaila Waste Centre Co-ordinator
([email protected]) must be contacted to arrange removal from the site.

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5. Decontaminating and Reinstating the Worksite

a. At the end of operation all workers must be checked for contamination on their PPE,
particularly the soles of boots.

b. If possible, all clothing, materials and equipment used in work with NORM should be
decontaminated by washing or wiping down and kept for reuse or disposed of as non-
radioactive waste. If this is not possible contaminated clothing, materials and
equipment should be stored in sealed labelled containers and disposed of as NORM
waste by an agreed disposal route, with guidance from the Rumaila Waste Centre Co-
ordinator ([email protected]).

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SOP13 – Management of NORM at the Rumaila Waste Centre

Intent

The intent of this procedure is to describe the steps to be taken to ensure the safe management of
NORM contaminated equipment and waste at the Rumaila Waste Centre (RWC). The scope of the
procedure applies to all incoming NORM contaminated equipment and material.

Roles and responsibilities

1. NORM competent person (personnel who have successfully completed the ROO level 2 basic
user training) – Personnel working at the RWC who are familiar with the risks associated with
NORM and the control measures required to mitigate these risks.

2. RWC Radiation Protection Supervisor (RPS) (personnel who have successfully completed an
RPS training course) – It is the responsibility of the RWC RPS to control the incoming and
outgoing NORM inventory and ensure that it is managed safely whilst being stored at the RWC.

NORM Waste Transfer Process

Generation and Identification of NORM Waste

1. The NORM waste is produced as a by-product of the production and processing of

hydrocarbons across the Rumaila oilfield. NORM contaminated waste contains Radium-226,
Radium-228 and their respective radioactive daughters from the Uranium-238 and Thorium-
232 decay series. These can be found deposited throughout the process in down-well
equipment, pipework, vessels and other instrumentation. NORM monitoring is carried out in
the field and measurements are taken by or under the supervision of personnel trained to
Radiation Protection Supervisor (RPS) level using contamination monitors. A screening
threshold of 3 counts per second (cps) above background (abg) is used to ensure all
contaminated material and equipment is identified at an early stage. No quantification is carried
out at this stage as it cannot be reliably carried out in the field. The monitoring requirements
are covered in more detail within the previous SOPs (numbers 01-06 and 10-12) contained in
ROO-ALL-HS-PRO-0109.

2. Labelling, Packaging and Temporary Site Storage

Once NORM contaminated material or equipment becomes waste, it is packaged, labelled and
stored on site according to the requirements of section 5.4 of ROO-ALL-HS-PRO-0109.
Equipment will only be held on operational sites for a short period until onward transport to the
RWC can be arranged (see below). More specifically, NORM contaminated equipment is
packaged by wrapping all open ends with heavy duty (1000 gauge) polythene sheeting and
sealing with ‘NORM Contaminated’ black / yellow warning tape. Bulk NORM material is
containerised as per SOPs 01-06 and 10-12 in ROO-ALL-HS-PRO-0109, this material is
nominally decanted into 205L clip-top drums which are marked as NORM contaminated using
the ‘NORM Contaminated’ tape. Yellow / black ‘NORM Contaminated’ tags are attached to
NORM contaminated equipment and drums containing NORM with details of the waste’s origins
to allow for traceability (see section 5.4 of ROO-ALL-HS-PRO-0109).

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3. Transport to RWC

All transport of NORM waste will be carried out by an authorised contractor on behalf of ROO.
The requirements of IAEA document SSR-6, Regulations for the Safe Transport of Radioactive
Material (2012 Edition), will be observed for all movements of NORM. Contaminated equipment
will nominally be transported as SCO-I (UN2913) on the assumption that the radioactive content
is due to Radium 226, Radium 228 and their radioactive daughter isotopes. Bulk NORM will
either be transported under transport exemptions for Class 7 dangerous goods (taking account
of the allowance for additional factor of 10 for NORM as per article 107 in SSR-6), as Excepted
Packages (UN2910) provided the packages satisfy the criteria, or LSA-I (UN2912). In cases
where no information regarding the specific activities is available, the latter will be used. See
SOP08 for more information.

4. Receipt at RWC

When NORM waste is received at RWC, it must be done so under the supervision of the RWC
RPS or other RPS qualified personnel designated by the RWC RPS. If there are any issues
identified with the transport arrangements, then these must be recorded and reported to the
Rumaila Waste Centre Co-ordinator([email protected]). If the packaging of any
received NORM waste is unsatisfactory then it must be repackaged for storage; open ends on
equipment must be wrapped with heavy duty (100 gauge / 250 micron) polythene sheeting with
yellow / black ‘NORM Contaminated’ tape and tags, other containers holding NORM must be
fully sealed and robust enough to withstand the storage conditions at the RWC.

All NORM waste must be routed to the designated NORM storage areas on the site and must
be segregated from all other waste. NORM waste types should be segregated, i.e.
contaminated equipment will be stored separately to contaminated sludge. Further segregation
will be implemented based on the measured levels of radioactivity to facilitate onwards disposal
to a state-operated facility at a later date. A record must be kept of every NORM contaminated
item and package received at the RWC with details of the originating site, receipt date,
contamination readings (cps abg), and dose rate readings (µSv/h). This record should be used
to populate a live NORM storage inventory reflecting all NORM contaminated items and
containers of NORM contaminated material at the RWC.

5. Temporary Storage

The storage arrangements at the RWC are such that no unauthorised access may be granted
to the NORM storage area. A full inventory of all NORM at the RWC will be kept up to date
allowing for full traceability. Periodic checks must be carried out by the RWC RPS to ensure
the condition of storage is satisfactory and dose rates outside the storage area are less than
2.5µSv/h where possible and less than 7.5µSv/h in any case. Where possible, NORM waste
will be stored under shade to prevent deterioration of containment from UV exposure.

6. Final Disposal

When disposal locations are designated by the Iraq Ministry of Environment, prior to transport,
NORM waste packaging and labels are to be inspected and be compliant to the requirements
in SOP-08. Following the final inspection of the condition of packaging, if deemed unsuitable
by the RWC RSP / ROO RPA then the NORM waste is to be repackaged prior to leaving the
site. The packaging must be robust to withstand the conditions of transport and be compliant
to National and International transportation requirements. A record must be kept of all items
leaving the RWC with proof of collection by the authorised contractor. The RWC NORM
inventory must be updated whenever an item leaves the site.

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9. WORKING WITH NORM FORMS
The following forms have been created to assist in the execution of the SOPs in section 8.0. The SOPs
instruct the user when each form is required. At the end of a job the associated NORM forms must be
held on file with the rest of the work pack and archived where appropriate.

The full list of NORM forms is as follows:

Form NORM01A – Record of Work Involving NORM

Form NORM01B – Record of Work Involving NORM (Workover)

Form NORM02 – Temporary NORM Store Inventory

Form NORM03 – Checklist for Contractors Working With NORM

Form NORM04 – Responsibility for a NORM Controlled Area

Form NORM05 – Controlled Area Dose Measurement Form

Form NORM06 – Annual Dose Record (Operations Personnel)

Form NORM07 – NORM Check and Gas Test Request (Vessel and Tank Entry)

Form NORM08 – NORM Check Request (Scrap)

Form NORM09 – NORM Check Request (break in containment points)

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FORM NORM01A – RECORD OF WORK INVOLVING NORM
1 Job Details

Site Name:

Date Job Started:

Description of Work scope:

2 Monitoring Details

□ SA-50
(Tick appropriate
Probe Used: Monitor Serial No.:
box)
□ SA-49

Location of Background
Background Reading (cps):
Reading:

Description of Equipment / Plant / Waste Results NORM

Meter User
Contaminated?*
(Include quantity of items, weights of any waste (cps
(Print Name)
generated, skip no’s, etc.) abg) (Yes / No)

□ NORM is present;

Recommendations:

□ personnel must wear a Tyvek suit, P3-rated RPE, Rubber or PVC boots and gloves. Smoking, chewing gum and the
consumption of food and drink are absolutely prohibited in the affected area without exception; drinking arrangements during
summer must be planned carefully.

□NORM is not present; work may proceed under normal condition.

Comments :

Dose Rate Measurement (if >200cps): µSv/h Dose Rate Monitor Serial No.:

Form Received and Checked by: (Insert RPS or RFP Name)

Additional Waste Generated? e.g. PPE / Rags / Plastic Sheeting Y/N

Work Area Monitored - Free of NORM Contamination (<3cps abg)? Y/N

*If a reading of 3cps abg or more is measured then the item is NORM contaminated, all NORM controls must be put in place as per the
relevant SOP in ROO-ALL-HS-PRO-0109

*contact with Hydar Naser 07704932982 for NORM transportation and storage area

Site manager (sign): Contractor HSE Adviser (sign):

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3 NORM Supervised Area – total work time

Name Employer Total day of task Total work time Start task date End work date

Additional Waste Generated? e.g. PPE / Rags / Plastic Sheeting Y/N

Work Area Monitored - Free of NORM Contamination (<3cps abg)? Y/N

4 Equipment / Waste Sent to RWC

Date Sent Description of Equipment / Waste Sent (reference section 2 - above)

5 Equipment Reinstated on Site

Description of Equipment Reinstated

Date Section 3 Completed
(reference section 2 - above)

Y/N

Y/N

6 Equipment / Waste Stored in Site Temporary NORM Store

Description of Equipment / Waste

Date
(reference section 2 - above)

7 Comments

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FORM NORM01B – RECORD OF WORK INVOLVING NORM (WORKOVER)

1 Job Details

Rig Name: Well No.:

Date:

2 Monitoring Details

□ SA-50
(Tick appropriate
Probe Used: Monitor Serial No.:
box)
□ SA-49

Background Reading (cps):

Measurement NORM
Description of Equipment
Range Contaminated?*
Quantity
(e.g. 5 ½” tubulars)
(cps abg) (Yes / No)

Additional Waste Generated? e.g. PPE / Rags / Plastic Sheeting Y/N

Work Area Monitored - Free of NORM Contamination (<3cps abg)? Y/N

Approval by NORM Competent Person

Name:

Signature:

Date:

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FORM NORM02 – Temporary NORM Store Inventory Facility Name: Page:

Removed to
Item Description of Item Removal Comments
Entry Date (e.g. RWC or
No. Date
(Section 2 of associated Form NORM01A) (e.g. Drum Number)
reinstated)

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FORM NORM03 – NORM RECORD FOR VESSEL / TANK ENTRY
Job Details

Vessel / Permit
Site Date
Tank No.

Pre-Job Checks

SA-50 Serial No. T202 Serial No. Background (cps)

Pre-Job Measurements

Locatio Contamination Reading Locati Contamination Reading

Dose Rate Reading (µSv/h) Dose Rate Reading (µSv/h)
n (cps abg) on (cps abg)

A D

B E

C F

Vessel / Tank Sketch

Draw a basic sketch of the vessel or tank indicating where each of the above measurements was taken

Condition Recommendation

All contamination readings below 3cps NORM is not present; work may proceed under normal Confined Space Entry
1 ☐
abg. Procedures. Recommendations 2-5 do not apply.

NORM is present; personnel must wear a Tyvek suit, P3-rated RPE, Rubber or PVC
Contamination readings of 3cps or more
2 ☐ boots and gloves. At least one person inside the confined space must wear an Instadose
abg.
dosimeter. Recommendation 3 or 4 applies.

No additional dose assessment required; work area is designated as a Supervised Area.

3 Dose rate readings less than 7.5µSv/h. ☐
Recommendations 4 and 5 do not apply

Dose assessment required. Work area is

4 Dose rates greater than 7.5µSv/h. ☐ Estimated dose: µSv
designated as a Controlled Area.

Estimated dose to individual greater Time limitation required to limit doses to Time limit (per
5 ☐ hours
than 300µSv for entire job. 300µSv. person):

Declaration

By signing this declaration, both parties agree that the pre-job checks have been carried out thoroughly. Where no NORM is present, no additional
controls are required. Where NORM is present, the radiological dose assessment is applicable and all recommendations for how the work must
proceed are clear. Personnel have been issued with Instadose dosimeters and the team carrying out the work have the necessary monitoring
equipment to take the required daily measurements. Finally, where an additional dose assessment has been carried out (see recommendation 4
above), the team carrying out the work understand and accept the risk associated with this dose.

ROO RPS (Name) Performing Authority (Name)

ROO RPS (Sign) Performing Authority (Sign)

Date Date

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Vessel / Tank Entry

- The ROO Static Team must take measurements of the dose rate at the beginning of each shift to determine whether the risk assessment is
still applicable. The maximum dose rate measured must be recorded in the table below for each day.
- If Recommendation 3 applies from the pre-job checks (see overleaf) then the ROO RPS must be notified if dose rates greater than 7.5µSv/h
are measured.
- If Recommendation 4 applies from the pre-job checks (see overleaf) then the ROO RPS must be notified if the dose rates measured are
more than 20% higher than the maximum measured by the ROO RPS at the start of the job (again, see overleaf).
- Upon notification by the ROO Static Team Leader, the ROO RPS must use the new dose rate measurements to carry out another
radiological dose assessment to determine if any additional control measures or time restrictions need to be imposed.
- At the end of each shift, the ROO Static Team Leader must sign that day’s entry in the below table to confirm that all personnel have been
checked for contamination before leaving the area and, if contamination was found, their PPE was dealt with according to
ROO-ALL-HS-PRO-0109 (SOP02).

Max. Dose Max. Dose

Personnel Personnel
Date Rate Signature Date Rate Signature
contam. free? contam. free?
(µSv/h) (µSv/h)

Close-Out

Provide a short but detailed description of To be completed by the ROO Static TL

any residual NORM waste left on the site
as a result of this work.

Carry out a final survey inside the vessel To be completed by the ROO Static TL
/ tank using a dose rate meter. If there
are any dose rates above background
levels, provide the readings and a
description of where these are.

Declaration

By signing this declaration, both parties agree that the close-out checks have been completed adequately. The ROO Static Team Leader has
handed all equipment back to the ROO RPS (Instadose dosimeters, dose rate meter and contamination meter). The ROO RPS is satisfied that
a final survey of the vessel / tank has been carried out. The ROO RPS has verified that the descriptions of waste left on site and of any residual
dose rates inside the vessel are accurate; a separate sheet should be appended where the boxes above do not provide adequate space.

ROO RPS (Name) ROO Static TL (Name)

ROO RPS (Sign) ROO Static TL (Sign)

Date Date

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FORM NORM04 – RESPONSIBILITY FOR A NORM CONTROLLED AREA
Requirement 24 of the IAEA Basic Safety Standards stipulates the controls required for work in a radiation Controlled Area.

The work with NORM, as described below, is covered by the standards mentioned above. The ‘Controlled Area’ in which this work is taking place, and the work itself,
is to be handed over to a contractor RPS as detailed below. This applies only in the context of the above stated standards.

All other responsibilities, legal and contractual, for the work remain with ROO.

Job Details

Work Location

NORM Job No.

Permit Number (if applicable)

Hand Over of Controlled Area to Contractor

Contractor

Description of Work to be Carried Out

Date Time

By signing below, I hereby hand over the Controlled Area in question to the above named contractor.

ROO RPS
Signed:

Print

By signing below, I hereby accept the ownership of the Controlled Area in question.

Signed: Contractor RPS

Print

Date

Hand back of Controlled Area to ROO RPS

te Time

By signing below, I hereby hand over the Controlled Area in question back to ROO.

Signed: Contractor RPS

Print

By signing below, I hereby accept the ownership of the Controlled Area in question.

Signed: ROO RPS

Print

Date

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FORM NORM05 - CONTROLLED AREA DOSE MEASUREMENT FORM

All operations personnel must be familiar with the use of any radiation dose rate monitor issued by
Industrial Hygiene before entering a controlled area.

All operations personnel must discuss the task to be performed with the site RPS before entering a
Controlled Area.

All operations personnel must complete this form when entering a Controlled Area, details to be
recorded include - name, task, date, exact time of entry and exit into a Controlled Area, dose recorded
on the monitor (include zero readings) and your signature.

Do not spend any longer within the barriers than the task requires.

This form must be returned to the site RPS upon completion of the task.

Task:

Date:

Exposure
Name Time In Time Out Reading on Signature
Monitor (µSv)

Form Received By (RPS Signature)

Date

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Form NORM06 - Annual Dose Record (Operations Personnel)
Name

Year

Time Dose
Location of Cumulative Cumulative dose
Date spent in Recorded
Work time to date to date (µSv)
area (µSv)

Any employee whose cumulative dose reaches 500µSv (0.5mSv) should be stopped from performing
tasks in a controlled area until the results have been discussed with the company RPA.

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FORM NORM07 – NORM CHECK AND GAS TEST REQUEST (VESSEL AND TANK ENTRY)

1 Job Details

Site Name:

Date

Description of Work scope:

Permit No.

Preparation for Vessel / Tank Entry

2

□ The vessel / tank has been opened □ The vessel / tank has been steamed

□ The vessel / tank has been ventilated □ Chemical circulation has been carried out.

□ A habitat has been erected around the vessel / tank manway

□ As much loose material has been flushed from the vessel /
with plastic sheeting on the ground to prevent contamination
tank as possible without entry using non-intrusive techniques.
spreading.

□ Excess material (e.g. water and oil) has been removed from □ There is only be one entry / exit point and personnel entering
the vessel / tank. the area is being kept to a safe minimum.

□ Confined space permit has been activated for NORM check entry.

Comments:

*sending *sending request by ROO site engineer to ROO RPS 72 hours in advance to attend the site

Site Engineer (sign): Contractor HSE Adviser (sign):

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FORM NORM08 – SCRAP NORM CHECK REQUEST (INSIDE AND 150 M. AROUND ROO
FACILITIES)

1 Job Details

Site Name:

Date

Description of Work
scope:

Preparation for Scrap NORM Checking

2

□ The scrap has been collected& isolated in □ The scrap ends have been enclosed by heavy
the designated area. duty sheet.

□ The Scrap has been organized, in a way to □ The scrap has been mounted on wooden or
have a room among them for checking. plastic pallet.

□ Coordination has been made between the

□ the Scrap Photos have been attached with the
scrap removing contractor and the site
request.
engineer for transporting.

□ The scrap has been exposed to oil. □ Approximately scrap items quantity:

Comments:

*sending request by ROO site engineer to ROO or Contractor SRPS 72 hours in advance to attend
the site.

Site Engineer (sign): Contractor HSE Adviser (sign):

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FORM NORM09 – BREAK IN CONTAINMENT POINT NORM CHECK REQUEST

Facility Name: Break in containment point in total:

Item
Name of break in containment point Location Comments
No.

Hot oil exposed items is not included,break in containment may go without a NORM checking, full PPE is recmmonded.

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10. APPENDIX A – RPS LETTER OF APPOINTMENT
Appointment to the Post of Radiation Protection Supervisor

Dear…………………………………..,

I am writing to confirm your appointment as a ROO Radiation Protection Supervisor (RPS).

I should also like to identify your responsibilities under the Safety Case and the ROO NORM Policy.

These are as follows:

1. Ensure that all relevant legislative and regulatory requirements, as outlined in section 3 of
the NORM Policy, are met.

2. Advise the Radiation Focal Points, Radiation Protection Adviser, Heads of Departments,
Contract and Other Personnel as advised on all matters relating to NORM held, handled,
stored or disposed of on the Site

3. Act as a contact between the Site Manager and contractor RPSs on the Site

4. Ensure that contractor RPSs follow their procedures and comply with the requirements of
the NORM Policy

5. Maintain the records required by the NORM Policy

6. Act as RPS for all operations carried out by Site staff that may involve exposure to NORM
contaminated equipment

7. Ensure that proper monitoring for NORM contamination is carried out in accordance with
the NORM Policy and that the contamination meters are calibrated and in working order

8. Ensure that worksite and radiation storage areas are maintained, safe and clean

Manager: RPS: Date:

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11. Appendix B – NORM Risk Assessment
The following risk / dose assessments are used to support the designation of Supervised and Controlled
Areas, and associated work controls. However, they do not replace the individual operational risk
assessments, which must be carried out to ensure that the assumptions made in these assessments
are valid.

Risk Assessment for Work with NORM (Excluding Vessel and Tank Entry)
This risk assessment applies to the routine site operations for handling NORM contaminated items and
sands, sludges or waxes. It does not apply to vessel cleaning operations. A separate risk assessment
has been prepared for tank and vessel cleaning work (see Section 7.2).

Plant and equipment may become contaminated with sand / scale / sludge and other waste deposits,
containing daughters from the decay series of uranium-238 and thorium-232. The main isotopes of
interest are radium-226, radium-228, thorium-228, lead-210 and polonium-210.

11.1.1 Assumptions
The maximum known specific activities of the NORM likely to be found in plant and equipment on ROO-
operated sites are 50Bq/g of radium-226, 15Bq/g of radium-228, and 15Bq/g of lead-210.

Note: It is assumed for these calculations that polonium-210 is in equilibrium with lead-210 and thorium-
228 is in equilibrium with radium-228.

It is assumed that personnel may work a total of up to 240 days per year.

The average NORM dust loading in air during NORM handling operations is conservatively estimated
as 0.25mg/m3 (5 times the WHO PM10 guideline value for a 24 hour mean) and any single person may
spend an average of up to one hour per day carrying out these operations, i.e. 240 hours per year.

The average dust loading in air during cutting operations is 2.5mg/m3 (50 times the WHO PM10
guideline value for a 24 hour mean) and any single person may spend an average of up to half an hour
per day carrying out these operations, i.e. 120 hours per year.

It is assumed that airborne dust is composed entirely of NORM with the specific activities quoted above.
Airborne dust has a Median Aerodynamic Diameter of 5µm. The ICRP worker breathing rate of 1.2
m3/h has been used throughout.

Based on previous readings, the maximum dose rate expected to be measured around NORM that
could lead to a whole-body dose (not involving vessel entry) is 7.5μSv/h. However, most exposures will
be less than 0.5μSv/h, with the majority of these expected to be measured at background levels.

11.1.2 External Exposure

It is assumed that a worker may be exposed to the maximum dose rate described above of 7.5μSv/h
for 60 hours per year and the lower dose rate of 0.5µSv/h for 300 hours per year. A worker could
therefore receive a whole-body dose of 600μSv in a year from external exposure.

11.1.3 Internal Exposure

The routes of entry through inhalation of particles and ingestion of particles are considered. Entry
through a cut in the skin can be ignored, as the likelihood is so small, and all cuts should be dressed
before work. The chemical and physical nature of scale is such that it is very likely that the oral route is
less significant than the inhalation route. Members of the workforce getting any lumps of scale in their
mouth would be expected to take steps to remove them and not swallow them. Similarly, any sand,
sludge or wax is not likely to be swallowed. The inhalation route could be significant under some
circumstances if precautions were not taken.
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swallowed. The inhalation route could be significant under some circumstances if precautions were not
taken.

11.1.3.1 Ingestion
From previous work carried out by the NRPB (Smith and Jones, 2003) it is assumed that up to 5mg of
material could be inadvertently ingested per hour. Using the working times quoted previously (390
hours total for handling and cutting operations) an employee may ingest up to 1.8g of NORM in any
single year without RPE. However, the recommended minimum of FFP3-rated masks provides a
protection factor of 20 (HSE guidance document HSG53) and so, if the correct PPE is worn, an
employee could potentially ingest 90mg. Assuming the average activities above, there is a potential
ingestion dose of 3.5µSv in a year.

11.1.3.2 Inhalation
Using the International Commission on Radiological Protection (ICRP) breathing rate of 1.2m3/h this
results in a total inhaled mass of 432mg without RPE. However, the recommended minimum of FFP3-
rated masks provides a protection factor of 20 (HSE guidance document HSG53) and so, if the correct
PPE is worn, an employee could potentially inhale 21.6mg. Assuming the average activities above,
there is a potential inhalation dose of 12.1µSv in a year.

11.1.3.3 Total Dose from Internal Exposure

The maximum committed dose to a worker during routine NORM operations on ROO-operated sites is
estimated at 15.6µSv in a year if the NORM controls described in this document are employed.

11.1.4 Total Dose from Internal and External Exposure

When working on ROO-operated sites, the maximum effective dose that a worker may receive in a year
is estimated at approximately 615.6µSv if the NORM controls, as described in this document, are
applied.

This dose is far less than the annual dose limit set for members of the public in the IAEA BSS and is
deemed acceptable for this type of work.

Note - where dose rates in a NORM work area are measured as 7.5µSv/h or greater, or NORM
operations not covered by these risk assessments are due to take place, a new risk assessment and
work instruction must be prepared and approved for use by the RPA. This work will then be performed
in a Controlled Area, with additional dose monitoring undertaken.

Risk Assessment for Entry into NORM Contaminated Tanks and Vessels
This risk assessment applies to personnel who are required to enter NORM contaminated tanks and
vessels for cleaning / desludging or other miscellaneous operations. This risk assessment assumes
that this is the only source of exposure for these personnel on ROO operated sites.

Again, the main isotopes of interest are radium-226, radium-228, thorium-228, lead-210 and polonium
210.

11.2.1 Assumptions
The maximum known specific activities of the NORM found in sands and sludges on ROO operated
sites are 50Bq/g of radium-226, 15Bq/g of radium-228, and 15Bq/g of lead 210.

Note: It is assumed for these calculations that polonium-210 is in equilibrium with lead-210 and thorium-
228 is in equilibrium with radium-228.

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Personnel spend a total of 20 hours each inside vessels or tanks per job and participate in up to one
such job per month.

The average airborne concentration during operations inside NORM contaminated vessels is
0.5mg/m3.

Airborne material is composed entirely of NORM with the specific activities quoted above and has an
Activity Median Aerodynamic Diameter of 5µm.

11.2.2 External Exposure

The external dose rates present inside NORM contaminated vessels / tanks vary considerably but it is
assumed that an external whole-body dose of up to 300µSv may be received in a single job. This
amounts to 3600µSv per year if this dose is received for all 12 jobs completed.

11.2.3 Internal Exposure

The routes of entry through inhalation of particles and ingestion of particles are considered. Entry
through a cut in the skin can be ignored, as the likelihood is so small, and all cuts should be dressed
before work. The chemical and physical nature of scale is such that it is very likely that the oral route is
less significant than the inhalation route. Members of the workforce getting any lumps of scale in their
mouth would be expected to take steps to remove them and not swallow them. Similarly, any sand,
sludge or wax is not likely to be swallowed. The inhalation route could be significant under some
circumstances if precautions were not taken.

11.2.3.1 Ingestion
From previous work carried out by the NRPB (Smith and Jones, 2003) it is assumed that up to 5mg of
material could be inadvertently ingested per hour. Using the working times quoted previously (20 hours
per job and 12 jobs per year) an employee may ingest up to 0.6g of NORM in any single year without
RPE. However, the recommended minimum of FFP3-rated masks provides a protection factor of 20
(HSE guidance document HSG53) and so, if the correct PPE is worn, an employee could potentially
ingest 30mg. Assuming the average activities above, there is a potential ingestion dose of 1.2µSv in a
year.

11.2.3.2 Inhalation
Using a modified breathing rate of 1.7m3/h for ‘heavy work’ and assuming 240 hours of occupancy this
results in a total inhaled mass of 204mg without RPE. However, the recommended minimum of FFP3-
rated masks provides a protection factor of 20 (HSE guidance document HSG53) and so, if the correct
PPE is worn, an employee could potentially inhale 10.2mg. Assuming the average activities above,
there is a potential inhalation dose of 5.7µSv in a year.

11.2.3.3 Total Dose from Internal Exposure

The maximum committed dose to a worker during routine NORM operations on ROO-operated sites is
estimated at 6.9µSv in a year if the NORM controls described in this document are employed.

11.2.4 Total Dose from Internal and External Exposure

The maximum effective dose that a worker might receive in a year from working inside NORM
contaminated vessels / tanks is estimated at approximately 3.6mSv if the NORM controls, as described
in this document, are applied.

This dose is above the IAEA dose limit for a member of the public (1mSv per year) but is well below
that set for workers (20mSv per year). The approach adopted by ROO follows the idea of classification
of workers (i.e. Category A and Category B workers) and therefore all ROO personnel involved in

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working with NORM are Category B workers as they are not expected to receive an annual dose greater
than 6mSv.

ROO Dose Limits

Any person engaged in working with NORM on a ROO Site not involving vessel or tank entry is subject
to an annual whole-body dose limit of 1mSv.

Any person engaged in work involving entry into NORM contaminated vessels or tanks is subject to an
annual whole-body dose limit of 4mSv. A record of doses to such personnel must be kept and
maintained by ROO.

Anyone who receives an estimated or measured dose greater than the applicable limit specified above
will have the cause of the dose investigated. If due to an unplanned event, suitable actions will be taken
to ensure that this cannot happen again. If received as part of normal working operations, the
procedures for these operations will be reviewed by the RPA and amended to ensure that it does not
happen again. Any special operations must be planned so that the risk assessment estimates that the
maximum dose likely to be received is less than 300μSv.

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12. APPENDIX C – NORM CONTINGENCY PLANS
Spill / Leakage of NORM contamination
The most likely incident involving NORM is the uncontrolled release of radioactive liquids and solids,
resulting in the contamination of the Site.

a. All leakages of NORM contaminated materials must be contained as soon as possible.

b. Personnel involved in the containment of NORM spills / leakages must wear full NORM PPE /
RPE (refer to section 5.7)

c. The extent of contamination must be identified and barriered-off.

d. The minimum number of people required for the clean-up operation should enter the
contaminated area.

e. No-one must exit this area without detailed contamination checks being carried out on PPE /
clothing. These checks must be recorded.

f. The RPS must monitor the area on completion of the clean up to ensure all contamination has
been removed.

g. Contact the RPA if further advice is required.

Personal Contamination
In the case of an individual’s personal clothing or skin becoming contaminated with NORM:

a. The RPS must monitor the individual’s hands and face. If NORM is identified, then personal
decontamination must be carried out. Care must be taken in order that the individual does not
ingest or inhale NORM contamination during this. Use of wet wipes advised.

b. The RPS must monitor the individual’s clothing, if NORM is detected the clothing must be
removed and segregated as NORM contaminated waste.

c. Contact the RPA for further advice.

Ingestion / Inhalation of NORM

In the case of an individual inhaling or ingesting NORM, or even if it is only suspected:

a. Work must be suspended, and the individual should drink plenty of water.

b. The Senior RPS must be contacted immediately ([email protected]).

c. The Senior RPS must then contact the RPA to discuss.

d. The RPA will then provide clear instructions to the RPS based on the specifics of the incident.

e. Always reassure the affected individual.

Documment No. ROO-ALL-HS-PRO-0109 Revision Date: 27/06/2021

Paper copies are uncontrolled This copy valid only at the time of printing

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