OSHA Hazard Information Bulletins
January 26, 1989
| MEMORANDUM FOR: | REGIONAL ADMINISTRATORS |
| |
| THRU: | LEO CAREY
Director
Office of Field Programs |
| |
| FROM: | EDWARD BAIER
Directorate of Technical Support |
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| SUBJECT: | Health Hazard Information Bulletin: Potential Health
Hazards Associated with Handling Pipe used in Oil and
Gas Production |
The State of Louisiana, Department of Environmental Quality has recently
issued a notification concerning a potential health hazard associated with
handling pipe used in oil and gas production that may be contaminated with
radioactive scale from naturally-occurring radioactive materials (NORM).
(Copies attached)
The concern is the possible inhalation and/or ingestion of scale particles
contaminated with radium-226 and possibly other radioactive material that may
become airborne during welding, cutting or reaming of pipe containing the
radioactive scale. The State of Louisiana is using the term for this
material Technologically Enhanced Natural Radiation (TENR), which is a
subgroup of a larger group, referred to as naturally occurring radioactive
materials or NORM.v
The investigation and regulatory control impact of most of these sources may
have been overlooked by Federal and State agencies in the past, while
stringent controls were placed on X-ray and other man-made sources of
radiation.
Compliance Officers should be aware of the potential radiation hazard to
workers due to TENR in the oil and gas industry.
Attachments
| State of Louisiana |
| |
| DEPARTMENT OF ENVIRONMENTAL QUALITY |
BUDDY ROEMER
GOVERNOR | PAUL H. TEMPLET,Ph.D.
SECRETARY |
RADIATION ASSOCIATED WITH OIL AND NATURAL GAS PRODUCTION AND PROCESSING
FACILITIES
1. INTRODUCTION - Technologically Enhanced Natural Radioactive Material
(TENR) Naturally-occurring radionuclides arc ubiquitous in the environment.
Under various circumstances, the radionuclides, primarily from the uranium
and thorium decay series, can contaminate the environment to the extent that
they pose real or potential public health risks. The investigation and
regulatory control of the impacts of most of these sources have been
overlooked by federal and state agencies in the past, while stringent
controls were placed on X-ray and other man-made sources of radiation. This
lack of strict controls has been due, in part, to the fact that the federal
government has limited jurisdiction over TENR, and control was previously
left up to the states, which often times did not have adequate programs or
staff to deal with the problem. TENR is a subset of a larger grouping
referred to as naturally-occurring radioactive materials (NORM), Regulations
to deal with NORM are being developed by a task force of the Conference of
Radiation Control Program Directors (CRCPD) and have been through six drafts
to date.
It should be noted, however, that considerable work has been done by the
CRCPD, the EPA, and individual states. The CRCPD established a task force to
assess the potential for problems nationwide with NORM and make
recommendations for implementation of effective control measures. Included in
the two documents published were identification of specific TENR problems, a
national inventory or NORM, and an evaluation of exposure pathways to man.
Additional work by EPA and individual states included a comprehensive health
effects study related to the use of slag from elemental phosphorus plants for
paving purposes in Idaho; an assessment of the phosphate mining industry in
Florida, including an evaluation of guidelines for homes built on reclaimed
mining lands; and complete radiation profiles of wet-process phosphoric acid
production, natural gas processing, lignite mining and alumina production in
Louisiana.
Much of this work was performed during the late 1970's and early `80's, and
many of the recommendations have not been acted on by the EPA and other
involved federal agencies. There does, however, appear at this time to be a
resurgence of interest in the NORM area, particularly by the CRCPD and
several interested states which make up the Conference membership. A
federal-state committee was recently established and will make formal
recommendations relative to the current situation with NORM and the need for
future activities.
While there are over 100 naturally occurring radionuclides, public health
problems are usually limited to the 30-odd radionuclides in the uranium and
thorium decay series because of their relative abundance and toxicity, and
they are generally the result of some technological enhancement of the
isotopes.
The increased incidence of bone cancer in radium dial painters and lung
cancer in fluorospar and uranium miners are examples of undesirable health
effects due to exposure to these radionuclides. Other examples of increased
population exposure to radiation include the radon problems in several
western states due to construction over radioactive tailings and the use of
reclaimed phosphate mining land in Florida.
Of particular interest to Louisiana is the growing awareness of related
problems of the radioactivity content of produced waters and contamination of
equipment and facilities in the oil and natural gas production and processing
industries.
II. PRODUCED WATERS
The occurrence of environmentally high concentrations of radioactivity,
specifically radium isotopes in oil field production waters (also called oil
field brines, produced water, produced wastewater or formation water) is well
documented [1, 2, 3, 4, 5, 6]. It appears that the radionuclides are leached
from the clay minerals and are associated with the decay of uranium and
thorium atoms [5, 8].
The radium levels observed in most saline produced waters from the Gulf
Coast Region exceed proposed and existing radium discharge limits applied to
other sectors [3]. Radium 226 and 228 activity was found in all 41 samples
of brines in one survey [5]. Activity ranged from 19 to 2800 pCi/l
(picoCuries/liter; 1 pCi = 1 x 10-(12)Ci). Seventy-six percent of the
samples tested contained 50 pCi/l of total radium. Produced water samples
from Louisiana platforms exhibited total radium activities of 605-1215 pCi/l
in a recent study [7].
EPA [3] reports that average open ocean surface waters contain about 0.05
pCi/liter; coastal waters probably do not generally contain much higher than
1 pCi/liter; proposed drinking water standards restrict the permissible
Ra-226 content to less than 5 pCi/liter (averaged); NRC regulations governing
the operations of licensees permit no more than 30 pCi/liter in liquid
discharges to unrestricted access areas. Fifty pCi/liter is the level of
activity that distinguishes between hazardous and nonhazardous wastes under
proposed EPA regulations.
It has been estimated that production water from the Leeville Oil Field
coastal Louisiana) contributed up to 1.76 Curies of radium to the marsh
around the field in a 5-year period [3]. It is our understanding that some
fields have been in production for 40 years or more. It is therefore possible
that the total radium released to the environment at these old fields could
be in excess of 10 Curies over the lifetime of the fields.
III. TENR CONTAMINATION OF EQUIPMENT AND FACILITIES
Recent Investigations have Identified radioactive "scale" resulting from the
production of oil and associated brines which contained Ra-226 concentrations
up to 100,000 pCi/gm [9]. Environmentally high concentrations of
naturally-occurring radionuclides (e.g. Ra-226, Pb-210) in precipitates
collected from the bottom of oil-water separators and from ditches and pits
used for disposal of production water have also been reported [1].
DEQ's Nuclear Energy Division (NED) has recently obtained information
indicating radium-226 radioactivity of up to 8,700 pCi/gm in soil
contaminated with radioactive scale at pipe storage areas [10, 11, 12].
Natural background radium-226 activity in Louisiana soils ranges from less
than one to about 7 pCi/gm [13]. EPA has proposed a cleanup limit for
radium-226 in uranium mill tailings of 5 pCi/gm (above background) in the top
15 cm (6 in.) of soil and 15 pCi/gm at depths below the top layer [10]. The
Conference of Radiation Control Program Directors has proposed remedial
action above 6 pCi/gm [10].
Contaminated piping from refineries has been found in scrap iron yards in
New Orleans, Baton Rouge, and Lake Charles. The State of Mississippi has
found contaminated pipe used in the construction of bleachers at schools.
And, NED has found the concentrations of radium in oil field production ponds
to be elevated. Readings made recently in a pipe reaming area at a pipe yard
in Houma were such that monitoring of employees would be required if it were
a licensed nuclear installation [10].
The magnitude of the problem is difficult to estimate, but it is not
unrealistic to expect contamination at all oil and gas production sites and
pipe handling facilities.
IV. CONCERNS
The following is a list of some of the questions and concerns we have that
are related to TENR-contamination in the oil and gas industry:
1. There are basically no regulations governing the handling and
disposal of TENR-contaminated materials except for uranium mill
tailings.
2. TENR-contamination in varying degrees of severity may exist at
every oil and gas production site and pipe handling facility in the state,
and may have also entered in substantial quantities into scrap yards and
metal reclamation facilities.
3. Radium-226 has a half-life of 1620 years, so these contaminated
sites will be of concern for centuries. Many of these sites, especially the
pipe yards, are within city limits and could easily be used for residential
or commercial purposes. If buildings were constructed over
radium-contaminated soil, the resulting radon concentrations could pose a
serious health threat.
4. The environmental consequences and health risks associated with
disposal of TENR-contaminated oil field wastes (e.g., incineration and land
farming) are largely unknown.
5. Workers employed in the area of cutting and reaming oil field
pipe may be exposed to dust particles containing levels of alpha-emitting
radionuclides that could pose very serious health risks.
6. Billions of gallons of produced water carrying TENR
contamination are being released annually to the environment, particularly in
coastal Louisiana. We have very little information on the fate and effects
of the materials in the aquatic and terrestrial environments and on potential
movement of TENR materials into food chains leading to human
consumption.
7. There are some very difficult questions concerning potential
liabilities for environmental contamination, workplace exposure to
radioactive materials, and necessary remedial measures.
V. RECOMMENDED ACTION PLAN
1. Develop and disseminate an interim policy for handling TENR
materials and protection for those working with contaminated pipe and
equipment. (Done)
2. Develop preliminary pathways and potential health effects of
exposure to TENR-contaminated materials (inhalation, ingestion, external
exposure), as well as fish and shellfish consumption, if
applicable.
3. Define and initiate a small strategic sampling effort to answer
immediate information needs.
4. Establish a task force to assist in dealing with the
TENR-contamination problem.
5. Research and develop legal framework for regulating
TENR-contaminated materials.
6. Develop and implement strategies for characterizing and
mitigating the problem. This is a nationwide problem, shared by all states in
one degree or another. It is therefore important to share information with
other states and attempt to develop strategies and solutions which have wide
applicability.
7. Identify potential sources of financial, human, and material
resources that could be applied to the problem.
8. Obtain funding to deal with the problem.
VI. REFERENCES
1. Gott, G.B. and J.W. Hill. 1953. Radioactivity in Some Oil
Fields of Southeastern Kansas. USGS Bull. 988E: 69-122.
2. Armbrust, G.F. and P.K. Kuroda. 1956. On the isotopic
constitution of radium (Ra-224/Ra-226 and Ra-228/Ra-226) In petroleum brines.
Trans. Am. Geophysics Union 37(2): 216-220.
3. U.S. Environmental Protection Agency. 1978. Natural
Radioactivity Contamination Problems. A report of the Task Force, prepared by
Conference of Radiation Control Directors, U.S. Nuclear Regulatory
Commission, U.S. Department of Health, Education and Welfare, and U.S.
Environmental Protection Agency.
4. Conference of Radiation Control Program Directors. 1981.
Natural Radioactivity Contamination Problems. Report No. 2.
5. Kraemer, T.F. and D.F. Reid. 1984. The Occurrence and Behavior
of Radium in Saline Formation Water of the U.S., Gulf Coast Region. Isotope
Geoscience 2:153-174.
6. Reid, David. 1983. Radium in Formation Waters: how much is it
of concern? Proceedings, 4th Annual Gulf of Mexico Information Transfer
Meeting, Mineral Management Service, New Orleans, LA.
7. Neff,, J.M., T.C. Sauer, and N. Maciolek. 1987. Fate and Effects
of Produced Water Discharges in Nearshore Marine Waters: Vol. I
II.
Technical Report to American Petroleum Institute, Washington, D.C.
8. Knecht, A.T. 1988. The impact of Produced Water Discharges
from Oil and Gas Operations in the Rstuarine Environment in Louisiana: A
Literature Review. University of New Orleans, Dept. Biological
Sciences.
9. Smith, A.L. 1987. Radioactive Scale Formation. Journal
Petroleum Technology. June: 697-706.
10. Scott, Max. 1988. Results, Comments, and Recommendations,
Radiation Survey. Texaco property, South Van Avenue, Houma,
Louisiana.
11. Louisiana Nuclear Energy Division. 1986. Investigation Report
on Radiation Contamination in a Pipeyard in Lafayette, LA, Nuclear Energy
Division, Louisiana Department of Environmental Quality.
12. Louisiana Nuclear Energy Division. 1988. Internal memorandum,
April 12, 1988, from Ronald L. Wascom (Nuclear Energy Division) to Dr. Mike
McDaniel (Assistant Secretary) Louisiana Department of Environmental
Quality.
13. Beck, J.N. et. al. 1986. Baseline Study of Environmental Radio
activity in Louisiana. Final Report of the Louisiana Board of
Reagents.
| State of Louisiana |
| |
| DEPARTMENT OF ENVIRONMENTAL QUALITY |
BUDDY ROEMER
GOVERNOR | PAUL H. TEMPLET,Ph.D.
SECRETARY |
| October 20, 1988 |
| |
TECHNOLOGICALLY ENHANCED NATURAL RADIOACTIVE MATERIAL
INTERIM POLICY
PIPE SCALE |
PURPOSE:
The purpose of this Interim policy is to establish radiation protection
procedures with regard to handling, storing and disposing of
technologically-enhanced natural radioactive material (TENR) found in pipe
scale or soil contaminated by the cleaning of pipe scale. The guidance given
is to be used in the development of procedures which will minimize exposure
to the radioactive materials while the extent of the potential hazard is
evaluated.
SCOPE:
This interim policy applies to any person who engages in activities which
technologically alter the natural sources of radiation or their potential
exposure pathways to man. There are presently no firm methods to deal with
the problem on a permanent basis.
CONTROL OF MATERIAL:
Due to the large volumes of waste involved, there is no easy solution to the
disposal of TENR-contaminated equipment or soil. The basic consideration, at
this time, is to consolidate the contaminated material and separate it from
non-contaminated material in an attempt to keep volumes as low as possible.
This also serves to facilitate retrieval when an acceptable disposal method
becomes available and to keep exposure to individuals as low as is reasonably
achievable.
Consolidated materials should be stored in a controlled area which has a low
occupancy. A radiation area survey should be performed and, if required, the
area should be posted in accordance with Section 422 of the Louisiana
Radiation Regulations.
Contaminated items should not be transferred to other individuals.
RADIOLOGICAL PRECAUTIONS:
The following precautions should be taken to minimize exposure to
TENR-contaminated materials:
Employees and contractors should be advised of the presence of this
contamination and of procedures to minimize exposure.
Direct skin contact with radioactive scale and solids should be
avoided to the extent reasonably possible.
Eating, drinking, smoking and chewing should not be allowed in the
work area where work is being performed on contaminated equipment or where
contaminated soil is being handled.
Personnel should thoroughly wash their hands and face after working
with contaminated equipment, and before eating, drinking, or smoking, and at
the end of the day.
The number of personnel in the work area should be kept to a minimum.
If possible, openings on contaminated equipment should be sealed or
wrapped in plastic. Work on contaminated equipment, such as cutting,
grinding, sand-blasting, welding, drilling, or polishing should be kept to a
minimum.
if work requires any action that might produce dust or if loose
contamination is suspected, the following additional precautions should be
taken:
A. A respirator appropriate for radioactive particulates should be
worn.
B. Suitable coveralls and gloves should be worn.
C. Activities should be conducted in well-ventilated areas to
which access has been restricted.
D. Plastic ground covers should be utilized to the extent possible
to contain contaminants and facilitate cleanup.
E. Gloves, respirators, coveralls, and rags should be
decontaminated or placed in double bags, sealed and held for proper
disposal.
F. The need for Personnel Monitoring and Bioassay should be
evaluated and provided if necessary.
In addition to the general guidance given above for pipe scale, there may be
other industrial operations, such as vessel entry, dismantling of equipment,
refurbishing of equipment or transportation, which may also require
precautionary procedures.
For additional information or clarification, contact the Department of
Environmental Quality, Nuclear Energy Division at 925-4518.
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