How will the new NORM strategy affect you?

The Government has launched a new strategy for the management of Naturally Occurring Radioactive Material (NORM). Its aim is to improve the management of NORM and remove the barriers to developing new treatment and disposal centres. It also sets out to improve data collection.

The new strategy, which came into force July 2014 will have a significant impact on the decommissioning industry and D3 is advising oil and gas companies to get to grips with it as soon as possible. Here are some of the key principles.

1. Waste Management Plans

The 2007 Low Level Waste Policy already states that anyone managing NORM wastes needs a waste management plan. The new strategy reiterates this and states that the plan needs to have a level of detail proportionate to the scale of waste produced and the holdings for the companies involved.

2. Early Interaction between Waste Producers and Disposal Providers

Waste producers and disposal providers are encouraged to interact earlier in the process so they can understand the type of waste that is being produced and ensure it is sent to the most appropriate disposal facility. This means that wastes with a lower activity are not sent to a disposal facility designed and engineered for more active wastes, which could result in a potential breach of regulations not to mention the Health & Safety implications of exposing workers to radioactive materials.

3. Minimising NORM Waste

The strategy encourages producers to follow the waste hierarchy and minimise the amount of NORM waste by:

· Proper segregation of waste.

· Reducing active levels of waste through decontamination.

· Using Characterisation and averaging of waste so that it can be exempted from regulatory control if it falls below pre-determined activity levels.

4. A Possible End to Discharging at Sea

The OSPAR Commission is dedicated to protecting and conserving the North-East Atlantic and its resources. It has stated that it may revisit the practice of disposal of NORM wastes into the sea from the oil and gas sector. This would lead to significant additional volumes of solid NORM waste being brought ashore, which would have a substantial impact on disposal routes. Oil and gas producers need to be aware of this potential development and start making contingency plans.

Estimating the quantities of NORM in offshore decommissioning projects is notoriously difficult. Email D3 to discuss how to do this and how you can adopt the new NORM strategy into your decommissioning plans.