norm management system (shell group hse ms) gert jonkers

NORM Management System(Shell Group HSE MS)

Gert JonkersEngineering & Analytical - GSEA/4 “Problem Solving”(Shell E&P Ionising Radiation/NORM HSE Expert CHP)

location

Shell Research & Technology Centre, AmsterdamP.O. 38000

NL-1030 BN Amsterdamthe Netherlands

2

E&P NORM WorkshopMuscat, February 21-24, 2005

tel. +31 20 630 [email protected]

G. Jonkers, GSEA/4 at SRTCAP.O. Box 38000, 1030 BN Amsterdam

FUEL GAS

GASSCRUBBER

1ST STAGESEPARATOR

GASSCRUBBER

FLARE

FLARE K.O.DRUM

PRODUCTIONTUBING

OVERBOARDPUMP

WATER FLOODINJECTION SEA WATER

BOOSTER PUMP

DE-AERATOR

SKIMMEDOIL PUMP

FLOTATIONCELL

METERINGPACKAGE

EXPORTLINEDEHYDRATOR2ND STAGE

SEPARATOROIL SHIPPING

PUMP

S.W.SERVICESCOOLERS ETC. SEA WATER

PUMP

WELLHEADS

PRODUCTIONMANIFOLD

EXPLOIT ALL a priori KNOWLEDGE ON E&P NORM

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Effective Radiation Protection ProgrammeIAEA, Operational Radiation Protection - Safety Guides, Safety Series 101 1990

IAEA, Recommendations for the Safe Use and Regulation of Radiation Sources in Industry, Medicine, Research and Teaching , Safety Series 102, 1990

Organisation & Management committed to

Safety & ALARP

Successful Personnel Selection & Training

EffectiveOccupational

RadiationControl

EffectivePublic

RadiationControl

EffectiveEmergency

Planning& Preparedness

ImplementationQuality

Assurance

1.Effective Management Structure

2.Clearly Documented Authorities, Responsibilities, Job descriptions

3.Adequate resources

4.Commitment to Safety & ALARP from all Employees

1.Appropriate Selection Criteria

2.Complete Post-Appointment Training

1. Identification of Potential Sources of Public Exposure

2.Adequately Derived and Documented Criteria to Limit Public Exposure

1. Identification of Components Requiring Formal Quality Assurance

2. Identification of Applicable Standards

3.Adequate Appraisal Regimes

1.Effective Control of Doses and Intakes

2.Adequate Control Standards

3.Effective Surveillance

1. Identification Potential Accident Situations

2.Evaluation Unidentified Accident Situations

3.Preparation Contingency Plans

4.Exercise Contingency Plans

5.Periodic Review Emergency Plans

ad 1) adequate corporate/site structure, seniority safety management, safety independent of production

ad 2) production/safety: publish policies, clear organisation chart

ad 3) production/safety: competent staff, adequate facilities

ad 4) training, appraisal ratings include safety performance

ad 1) documented qualification requirements for all levels, minimum age requirements, identified and documented medical requirements

ad 2) formal review training requirements, documented training objectives, adequate scope of training programme, induction training to rectify deficiencies

ad 1) adequate control of source, provision of physical barriers, provision of administrative controls

ad 2) adequately derived standards, adequately documented standards, pre-determined reference and action levels

ad 3) adequate monitoring of workplace, appropriate personal dosimetry, assessment of results and data of occupational radiation control

ad 1) adequate control of public doses due to > accident situations, > routine releases,

> transport of radioactive materials, > radioactive waste

ad 2) individual and collective doses

ad 1) location, causead 2) evaluation of

non-radiological conseq./ hazard / personnel-at-risk / consequences

ad 3) statements potential situations & identifiable hazards, provision of adequate communicat., recommended course of action, availability emergency equipment, notifications outside organisation, plans for exposed personnel

ad 4) degree of involvement, frequency

ad 5) scope/frequency review

ad 1) equipment / procedure oriented

ad 2) satisfy self-determined / external / national standards

ad 3) defined appraisal committee / frequency of appraisals / scope of appraisals

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1960 1970 1980 1990

Safety

Assurance

Past Present TRENDS

Safety engineers / officers Line management responsibility supported by safety (HSE) advisers Reaction to accidents Prevention of accidents Accidents accepted Accidents can severely erode the reputation/results of the Company Prescriptive rules Goal setting rules risk based Safety was a side issue HSE is a core issue

equipmentfocus

Human Error Focus

Line Management

Focus

Safety(HSE)

ManagementSystem

Evolution of HSE Management Systems

2000

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Leadership and CommitmentPolicy and Strategic

Objectives

Management Review

Corrective Action and Improvement

Audit

Organisation, Responsi-bilities, Resources,

Standards and Documents


Monitoring

Planning and Procedures

Hazards and Effects Management

Implementation

Corrective Action

HSE Management System Structure

CHECK

DO

PLAN

FEEDBACK

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Leadership & Commitment

Specific requirements for (E&P) NORM (draft)

Company Management shall ensure that extracted natural resources (e.g. Oil, Gas, Tar sands, Coal) are evaluated on NORM contents and that methods to reduce production are considered.

All persons that can potentially be exposed to NORM shall be informed.

Site owner shall assess the risk of NORM contained in feedstock or purchased materials based on extracted natural resources and minimize the quantities imported.

Site owner shall check and have an inventory of accumulations of NORM in company and contractor equipment.

Management to make sure that a qualified person is assigned to advice on dealing with the NORM. Accountability for managing NORM rests with site management.

Receivers of products and waste streams from contaminated installations shall be made aware of the NORM contents.

Company and contractor organisations maintaining or demolishing the installations shall be made aware of contaminations and the correct disposal route.

Emergency response plans shall deal with the reputation aspects of inadvertent handover or disposal of NORM containing product, equipment or waste

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Field/Asset HSE advisors (Radiation Protection Technicians)(HSE critical activities)

CompanyManaging Director/Board

Radiation (NORM) Advisory CommitteeChair: HSE Manager

Members: Managers of “NORM-affected” operations (incl. contractors)Company Radiation Focal Point

Operations Radiation Focal Point

Field/Asset Radiation Focal Points

External Radiation Protection

Advisor

Potential Embedment of NORM (IR Protection) Know How

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Hazard and Effects Management Process (HEMP)

Are people, environment or assets exposedto potential harm?

What are the causes and consequences?How likely is loss of control?What is the risk and is it ALARP?

Can the causes be eliminated?What controls are needed?How effective are the controls?

Can potential consequences or effects be mitigated?What recovery measures are needed?Are recovery capabilities suitable and sufficient?

Identify

Assess

Control

Recover

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222Rn 218Po +

234mPa 234Pa + h

emission of mono-energetic, fast (MeV) He nuclei

emission of poly-energetic, fast (keV< >MeV) electrons

emission of mono-energetic, penetrative (keV< >MeV) photons

214Pb 214Bi +

MODES OF (NATURAL) DECAY

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RADIATION PENETRATION CHARACTERISTICS

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POTENTIAL EXPOSURE & ASSESSMENT

Ingestion (Bq/L, Bq/g) contaminates body (stomach)

Inhalation (Bq/m3) airborne & radon contaminates body (lungs)

Irradiation by -photons from outside the body

Contamination (Bq/cm2) of the outside body (skin)

Intake (Bq) & DCCinh (Sv/Bq): internal dose (Sv)

Intake (Bq) & DCCing (Bq/Sv): internal dose (Sv)

Dose rate (Sv/h) / exp. Time (h):external dose (Sv)

surface dose rate (Sv/h per Bq/cm2) / exp. time (h):………

skin dose (Sv)

Sum whole body dose (Sv)Dose Conversion

Coefficient (Bq/Sv, ex ICRP #72)Radionuclide Specific

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HAZARD THREAT

BARRIERS

RECOVERYPREPAREDNESS

MEASURES

CONSEQUENCE

TopEvent

SCENARIO

CONSEQUENCE

CONSEQUENCE

The Bow Tie model

Control (keep within control limits) Prepare for emergencies

Objective: reduce likelihood(pro-active/preventative)

Objective: mitigate consequences and re-instate (reactive)

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Possible End Consequences from a Top Event

PeopleNORM no acute effectschronic exposure

Reputation

Environmentdischarges to air & water; waste

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Leadership and Commitment

Policy and Strategic Objectives

Management Review


Audit

Organisation, Responsi-bilities, Resources,

Standards and Documents


Monitoring

Planning and Procedures

Hazards and Effects Management

Implementation

CorrectiveAction

HAZARD THREAT

BARRIERS

RECOVERYPREPAREDNESS

MEASURES

CONSEQUENCE

TopEvent

SCENARIO

CONSEQUENCE

CONSEQUENCE

Control (keep within control limits) Prepare for emergencies

Objective: reduce likelihood(pro-active/preventative)

Objective: mitigate consequences and re-instate (reactive)

HSE Commitment and Risk Management

HSE Commitment

tasksresponsibilitiescompetencies

procedures

Target

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FROM DOSE TO RISK LEVELS

Hazard Identification: • NORM exposure within in stochastic (chronic) dose regime, i.c. no deterministic (acute)

effects• Epidemiological data shown conclusively that ionising radiation can cause cancer in

human beings.

Dose-Response Relationship: • Absorbed dose in tissue is the physical fundamental quantity, that determines the

response, NOT the source of radiation;• Estimates stem from special groups exposed well above natural levels, like Japanese

bomb survivors, uranium miners, radium dial painters;• Linear function of dose without a threshold (LNT-model; UNSCEAR 5% per Sv).

Exposure Assessment:• Similar for (naturally occurring) radionuclides and other hazardous chemicals except that

external exposure to penetrating radiation is an important pathway.

Risk Characterisation:• Relatively straightforward, and generally focuses on fatal cancers as the endpoint of

concern (LNT-model; UNSCEAR = 5% per Sv adopted by ICRP).

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Quantified Risk Assessment Levels (QRA)

Low, consider cost effective alternatives

Fundamental improve-ments needed. Only to be considered if there are no

alternatives and people are well informed.

Too high, significant effort required to improve.

High, investigate alternatives

Negligible, maintain normal precautions

Intolerable

The ALARP or Tolerable RiskRegion (Risk is tolerated only and risks have to be managed to ALARP)

Broadly acceptable region.

No need for detailed working to demonstrate ALARP

Individual Risk Per Annum

10-3 die per year

10-6/y

10-4 die per year

10-5/year

public dose limit

natural background dose

NORM source constraint

practice source constraint

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Operations - External Radiation Hazard

TARGET Minimisation of Exposure to Penetrative Radiation Emitted by NORM Deposits

TIME Minimise the time spent in proximity of NORM affected facility parts.

DISTANCE Maximise the distance to NORM affected facility parts.

SHIELDING Maximise the shielding between personnel and NORM affected facility parts.

TARGET Minimisation of Exposure to Penetrative Radiation Emitted by NORM Deposits

TIME Minimise the time spent in proximity of NORM affected facility parts.

DISTANCE Maximise the distance to NORM affected facility parts.

SHIELDING Maximise the shielding between personnel and NORM affected facility parts.

BarriersSeparation (Time & Distance)

Administrative (Training, Warning)

Procedural



Procedural

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Maintenance - Internal & External Radiation Hazard

TARGET Prevention of Internal Contamination by Naturally Occurring Radionuclides in Deposits (NORM)

Ingestion Avoid direct skin contact with LSA deposits. No eating, drinking etc. at the workplace. Use PPE (e.g. gloves).

Inhalation Avoid dust generating operations. Use PPE (e.g. respiratory protection).

External Time (Distance/Shielding) applies as well.

TARGET Prevention of Internal Contamination by Naturally Occurring Radionuclides in Deposits (NORM)

Ingestion Avoid direct skin contact with LSA deposits. No eating, drinking etc. at the workplace. Use PPE (e.g. gloves).

Inhalation Avoid dust generating operations. Use PPE (e.g. respiratory protection).

External Time (Distance/Shielding) applies as well.

Barriers

Separation (Time & Distance)


ProceduralRepressive (ventilation, dust filtration)



ProceduralRepressive (ventilation, dust filtration)

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TARGET Reducing both External and Internal Dose by Naturally Occurring Radionuclides in Deposits (NORM ) from former Gas/Oil Production Activities to an Acceptable Level for Future Inhabitants

Ingestion Determine amount of radioactivity entering food chain.

Inhalation Potential (topsoil) dust activity levels extremely low.

External (Sub)soil activity levels sufficient low.

TARGET Reducing both External and Internal Dose by Naturally Occurring Radionuclides in Deposits (NORM ) from former Gas/Oil Production Activities to an Acceptable Level for Future Inhabitants

Ingestion Determine amount of radioactivity entering food chain.

Inhalation Potential (topsoil) dust activity levels extremely low.

External (Sub)soil activity levels sufficient low.

ABANDONMENT - Internal & External Radiation Hazard

BarriersAdministrative (Training, Warning)

ProceduralPreventative (area cover, collection)

Repressive (ventilation, dust filtration)

Recovery PreparednessCurative (cleanup, remediation)

Compensatory

BarriersAdministrative (Training, Warning)

ProceduralPreventative (area cover, collection)

Repressive (ventilation, dust filtration)

Recovery PreparednessCurative (cleanup, remediation)

Compensatory

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Review & Corrective Actions

Dose records and/or dose assessments, NORM surveys, NORM analysis results, NORM production (notification & licensing?) should be reviewed regularly by the Radiation

Advisory Committee defining Corrective Actions for Improvement

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“OPERATIONS” NORM (external/contamination) radiation survey

dose readings > 0.5 Sv/h NORM contaminatedor contamination readings > 50 bg signpost areas

0.1 Sv/h < dose readings < 0.5 Sv/h NORM suspector5 bg < contamination readings < 50 bg

dose readings < 0.1 Sv/h no NORM restrictionsand contamination readings < 5 bg

SYSTEMATIC APPROACH TO PROTECTION AGAINST “NORM”

“MAINTENANCE” NORM (external/contamination) readings ad hoc

NORM contaminated: take external and contamination readings for open tanks/vessels, working hours, asses dose, Waste Storage

NORM suspect: take external and contamination readings for open tanks/vessels, record working times, take ‘representative’ sample Analyse for final classification of waste: normal / NORM

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Risk of Radiation DosesCompare with Natural Background Dose

norm management system (shell group hse ms) gert jonkers

Documents

safety series

documented standards

adequate facilitiesad

safety performancead

seniority safety management

adequate control of

organisation management

documented criteria