How to manage NORM during a decommission
During a phase of decommissioning, anyone working within an oil or gas facility knows the extensive problems caused by NORM, short for Naturally Occurring Radioactive Material. NORMs can be costly, time consuming and ultimately damaging for the industry, so it is important that they are managed properly wherever possible.
NORMs are particularly damaging because of three different factors:
- NORM waste is made even more dangerous when it is inevitably mixed with other hazardous substances.
- NORM waste cannot be easily identified and can remain undetected.
- NORM can remain even after cleaning procedures have been carried out.
Anyone maintaining an oil or gas facility needs to be aware of the fact that even if NORM is not detected during or after the shutdown of a plant, it should still be regarded as a long-term recurring issue that could be identified at any point during operational practices. If this mind-set is adhered to, then this will save any facility time and money, leaving management prepared for any set-backs NORMs may incur.
Surveying processes need to be issued on a regular basis so that the adverse effects of NORMs is limited and kept to a minimum with the facility. Working in this way will ensure that management has peace of mind when the acceptance criteria for transporting materials is so important within any oil or gas operation.
Continual consultation with Radiation Protection Advisers (otherwise known as RPAs) and Radiation Waste Advisers (also referred to as RWAs) is also crucial when understanding the importance of dealing with NORMs. Not only is this a legal requirement for anyone working with these waste materials, but it is a steadfast way of understanding these materials at the planning stages of any shutdown or project.
This blog post is a helpful source in understanding more about NORM during decommissioning for any gas or oil facility. Published by Tracerco, this is a firm that hosts an array of certified RPAs who understand the problems they incur more than anyone in the business.
What is NORM?
Every mineral and raw material contain what are called radionuclides of natural origin. While the vast majority of human activity involving these minerals and raw materials is of no cause for radiative concern, some activities do increase the exposure to ionising radiation. This is known by the acronym NORM.
Burning coal, making and using fertilisers and oil and gas production are all common cases which result in NORM, meaning processes must be in place to deal with the heightened exposure. The term NORM also exists to distinguish ‘natural radioactive material’ from anthropogenic sources of radioactive material, such as those produced by nuclear power, where the radioactive properties of a material is the reason for human interest.
As more NORM hazards have been identified over time, industries have become increasingly subject to monitoring and regulation, although the World Nuclear Association says there is little consistency among these regulations, meaning what is considered as radioactive waste in one country may not be in another.
In terms of oil and gas production, the extent of NORM depends largely on the radioactivity of the reservoir rock and salinity of water co-produced from the wells. The more saline the water, the more NORM is likely to be found. This means that older wells tend to exhibit higher degrees of NORM than their younger counterparts.
Fracking is a gas extraction technique which can lead to significant release of NORM in some geological environments. Generally, however, external exposure to NORM in the oil and gas industry is low enough not to require protective measures to make sure workers stay under their annual does limits.
By Andrew Smith, Tracerco
UK must stop blundering into high carbon choices warns CCC
The UK Government must end a year of climate contradictions and stop blundering on high carbon choices, according to the Climate Change Committee as it released 200 policy recommendations in a progress to Parliament update.
While the rigour of the Climate Change Act helped bring COP26 to the UK, it is not enough for Ministers to point to the Glasgow summit and hope that this will carry the day with the public, the Committee warns. Leadership is required, detail on the steps the UK will take in the coming years, clarity on tax changes and public spending commitments, as well as active engagement with people and businesses across the country.
"It it is hard to discern any comprehensive strategy in the climate plans we have seen in the last 12 months. There are gaps and ambiguities. Climate resilience remains a second-order issue, if it is considered at all. We continue to blunder into high-carbon choices. Our Planning system and other fundamental structures have not been recast to meet our legal and international climate commitments," the update states. "Our message to Government is simple: act quickly – be bold and decisive."
The UK’s record to date is strong in parts, but it has fallen behind on adapting to the changing climate and not yet provided a coherent plan to reduce emissions in the critical decade ahead, according to the Committee.
- Statutory framework for climate The UK has a strong climate framework under the Climate Change Act (2008), with legally-binding emissions targets, a process to integrate climate risks into policy, and a central role for independent evidence-based advice and monitoring. This model has inspired similarclimate legislation across the world.
- Emissions targets The UK has adopted ambitious territorial emissions targets aligned to the Paris Agreement: the Sixth Carbon Budget requires an emissions reduction of 63% from 2019 to 2035, on the way to Net Zero by 2050. These are comprehensive targets covering all greenhouse gases and all sectors, including international aviation and shipping.
- Emissions reduction The UK has a leading record in reducing its own emissions: down by 40% from 1990 to 2019, the largest reduction in the G20, while growing the economy (GDP increased by 78% from 1990 to 2019). The rate of reductions since 2012 (of around 20 MtCO2e annually) is comparable to that needed in the future.
- Climate Risk and Adaptation The UK has undertaken three comprehensive assessments of the climate risks it faces, and the Government has published plans for adapting to those risks. There have been some actions in response, notably in tackling flooding and water scarcity, but overall progress in planning and delivering adaptation is not keeping up with increasing risk. The UK is less prepared for the changing climate now than it was when the previous risk assessment was published five years ago.
- Climate finance The UK has been a strong contributor to international climate finance, having recently doubled its commitment to £11.6 billion in aggregate over 2021/22 to 2025/26. This spend is split between support for cutting emissions and support for adaptation, which is important given significant underfunding of adaptation globally. However, recent cuts to the UK’s overseas aid are undermining these commitments.
In a separate comment, it said the Prime Minister’s Ten-Point Plan was an important statement of ambition, but it has yet to be backed with firm policies.
Baroness Brown, Chair of the Adaptation Committee said: “The UK is leading in diagnosis but lagging in policy and action. This cannot be put off further. We cannot deliver Net Zero without serious action on adaptation. We need action now, followed by a National Adaptation Programme that must be more ambitious; more comprehensive; and better focussed on implementation than its predecessors, to improve national resilience to climate change.”
Priority recommendations for 2021 include setting out capacity and usage requirements for Energy from Waste consistent with plans to improve recycling and waste prevention, and issue guidance to align local authority waste contracts and planning policy to these targets; develop (with DIT) the option of applying either border carbon tariffs or minimum standards to imports of selected embedded-emission-intense industrial and agricultural products and fuels; and implement a public engagement programme about national adaptation objectives, acceptable levels of risk, desired resilience standards, how to address inequalities, and responsibilities across society.
Drax Group CEO Will Gardiner said the report is another reminder that if the UK is to meet its ambitious climate targets there is an urgent need to scale up bioenergy with carbon capture and storage (BECCS).
"As the world’s leading generator and supplier of sustainable bioenergy there is no better place to deliver BECCS at scale than at Drax in the UK. We are ready to invest in and deliver this world-leading green technology, which would support clean growth in the north of England, create tens of thousands of jobs and put the UK at the forefront of combatting climate change."
Drax Group is kickstarting the planning process to build a new underground pumped hydro storage power station – more than doubling the electricity generating capacity at its iconic Cruachan facility in Scotland. The 600MW power station will be located inside Ben Cruachan – Argyll’s highest mountain – and increase the site’s total capacity to 1.04GW (click here).
Lockdown measures led to a record decrease in UK emissions in 2020 of 13% from the previous year. The largest falls were in aviation (-60%), shipping (-24%) and surface transport (-18%). While some of this change could persist (e.g. business travellers accounted for 15-25% of UK air passengers before the pandemic), much is already rebounding with HGV and van travel back to pre-pandemic levels, while car use, which at one point was down by two-thirds, only 20% below pre-pandemic levels.