Implementing a Corporate-wide Policy For Dealing With Naturally Occurring Radioactive Material
Authors: Woods S.E. , Abernathy S.E. 
Published: March 2010

Abstract
Radiation exposure at levels associated with oil and gas industry naturally occurring radioactive materials (NORM) is not known to cause injury; however, many companies have adopted policies to address NORM because of increased public concern and regulatory awareness of such exposure. When a company "develops" and implements "a corporate-NORM- policy (CNP), the company must thoroughly evaluate every aspect of its operation to determine at what point, NORM is encountered and what processes tend to concentrate NORM to regulated levels. Once a company identifies all of its sections that have elevated levels of NORM (or the potential for such), the interrelationships among these sections must be evaluated. After the company identifies all possible, problem sections, evaluation, interpretation and clarification of the existing and proposed regulations must begin. Operations in, one country must be evaluated both with respect to that country's regulations and the regulations of foreign countries in which the company does business. The main points a company must evaluate are employee exposure, environmental contamination; facility and equipment contamination, the logistics of moving between facilities covered by different regulations, trends of proposed regulations, disposal of, NORM awareness training and surveyor equipment and training. A company should incorporate each of these points into its CNP and should implement its CNP in a standardized way into each part of its operation. By doing so, the CNP will provide the stability and means for gathering accurate, reproducible data and the CNP will have the flexibility to address new and proposed regulations and subsequent requirements.

Introduction
Radioactivity associated with nuclear power and nuclear weapons has received significant recognition and press. A more common but much less publicized type of radioactive material is naturally occurring radioactive material (NORM). NORM is present in our natural environment and is contained in many common items. For example, foods such as Brazil nuts, mustard, mint, cinnamon, ginger and black pepper contain small amounts of radioactivity from the soil in which they grew. Mineral waters, tobacco products, natural gas, peat moss, fertilizers, gas lantern mantles and even salt substitutes also contain NORM. The materials removed from water as it is treated before being piped into our homes, as well as burned coal ashes (which are commonly used as in additive in cement, bricks, road aggregate and wool insulation) can be radioactive(1).
NORM is no stranger to the oil industry, either. The scale that accumulates on the inside surface of oilwell pipes and processing equipment may contain NORM. So can the sludge from the bottoms of oil storage tanks. Since the discovery of elevated levels of radiation-associated scaled production tubing in Mississippi and Louisiana, many U.S. states are enacting regulations to control NORM.
To protect the environment, public, employees and facilities, many companies are screening equipment and facilities to ensure adequate protection. When a company screens equipment and facilities, the people conducting the surveys should undergo adequate training and use appropriate survey equipment. Once they are trained and appropriately equipped, the personnel are ready to investigate the problem.