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Guidance on

Handling Naturally Occurring
Radioactive Materials

IMCA SEL 024
September 2009
International Marine
Contractors Association
www.imca-int.com
AB







AB
The International Marine Contractors Association
(IMCA) is the international trade association
representing offshore, marine and underwater
engineering companies.

IMCA promotes improvements in quality, health, safety,
environmental and technical standards through the publication
of information notes, codes of practice and by other
appropriate means.

Members are self-regulating through the adoption of IMCA
guidelines as appropriate. They commit to act as responsible
members by following relevant guidelines and being willing to be
audited against compliance with them by their clients.

There are two core activities that relate to all members:
 Competence & Training
 Safety, Environment & Legislation

The Association is organised through four distinct divisions,
each covering a specific area of members’ interests: Diving,
Marine, Offshore Survey, Remote Systems & ROV.

There are also five regional sections which facilitate work on
issues affecting members in their local geographic area –
Asia-Pacific, Central & North America, Europe & Africa, Middle
East & India and South America.


IMCA SEL 024

This guidance was prepared for IMCA by a workgroup under
the direction of its Safety, Environment & Legislation (SEL) Core
Committee.


www.imca-int.com/sel



The information contained herein is given for guidance only and endeavours to
reflect best industry practice. For the avoidance of doubt no legal liability shall
attach to any guidance and/or recommendation and/or statement herein contained.
© 2009 IMCA – International Marine Contractors Association

Guidance on Handling Naturally Occurring Radioactive Materials

IMCA SEL 024 – September 2009



1 Executive Summary .............................................................................................. 1
2 Introduction ........................................................................................................... 1
3 Glossary of Terms ................................................................................................. 2
4 What is NORM? ..................................................................................................... 3
4.1 The Production of NORM ................................................................................................................................... 3
4.2 What is the Risk to Health of NORM? ............................................................................................................ 3
4.3 Other Forms of Radioactive Material Encountered in the Oil & Gas Industry ...................................... 4
5 Identifying Radiological Hazard ........................................................................... 5
6 Considerations for Operational Planning ........................................................... 5
6.1 Risk Assessment ..................................................................................................................................................... 5
6.2 Operation of Radiation Monitors and Other Detection Equipment ........................................................ 5
6.3 Training and Awareness ....................................................................................................................................... 6
7 Guidelines for Operational Activities when Handling NORM .......................... 7
7.1 Control of Exposure ............................................................................................................................................. 7
7.2 Contingency ............................................................................................................................................................. 7
7.3 Preparation, Precautions and Decontamination ............................................................................................. 7
7.4 Divers ........................................................................................................................................................................ 8
7.5 Transportation of NORM to the Decontamination Contractor ............................................................... 9
8 Regulatory Framework ....................................................................................... 10
Appendices
1 Typical NORM/LSA Checklists .......................................................................... 11
2 Handling of Potentially NORM Contaminated Equipment ............................ 12


IMCA SEL 024 1
1 Executive Summary
Small quantities of solid naturally occurring radioactive materials (NORM) can be generated by petroleum
production facilities and associated pipes, flowlines and other equipment which may be handled by IMCA
members’ personnel. Correct handling of NORM is important to avoid issues of occupational health and
safety, environmental protection, waste disposal and management. If NORM is handled correctly, it poses no
hazard to health or the environment.
This document has been issued to provide guidance for members on NORM and how it should be handled –
including a brief technical background on what NORM is, the context of the hazards involved in its handling,
and considerations for properly handling and disposing of NORM.
2 Introduction
‘NORM’ is the name used to describe the naturally occurring radioactive material encountered in the oil and
gas industry. Sometimes it is referred to as ‘LSA’ (low specific activity) material. It should be noted that
NORM (LSA scale) can be found in a variety of forms, and can be encountered during oil production in gas and
oil wells. Additionally, much process plant in the oil, gas and produced water handling systems may be
internally contaminated with NORM, and sea-water pumps and injection equipment can become contaminated
by low levels of radioactivity after many years’ usage, owing to background levels of radiation in seawater.
IMCA recognises that work with radioactive material can be an emotive subject. Ill-considered use of
terminology can cause workforce concerns and possible media attention with subsequent likelihood of poor
publicity. This may result in regulatory bodies acting from the very best motives to implement regulations not
suited or intended for use in the offshore oil and gas industry.
The purpose of this document is to provide readers with a clear insight into the relatively low-risk nature of
working with NORM found in the offshore oil and gas industry. The document provides guidelines for
members on monitoring and handling of such materials, information on the substances involved and the risks
presented thereby, and a brief overview of some of the regulations applicable to the transport of radioactive
waste.
Further information on the management of NORM in the oil and gas industry can be found in the OGP
document OGP 412 – Guidelines for the management of naturally occurring radioactive material (NORM) in the oil &
gas industry – to which this IMCA document makes reference. The OGP document can be downloaded from
http://www.ogp.org.uk/pubs/412.pdf
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3 Glossary of Terms
ADR The European Agreement concerning the international carriage of Dangerous Goods
by Road
Background radiation The sum of radiation emitted from a variety of natural and artificial radiation sources in
the local environment around us
Becquerel Becquerel (Bq) is the SI unit of measurement of radioactivity
IMDG The International Maritime Dangerous Goods Code
Isotopes Any of the different forms of an element each having different atomic mass. Isotopes
of an element have nuclei with the same number of protons but different numbers of
neutrons
LSA Low specific activity
NORM Naturally occurring radioactive material that can be encountered in the oil and gas
industry. Sometimes it is referred to as low specific activity (LSA) material. For the
purposes of this document such materials will be referred to hereafter as NORM
OGP International Association of Oil & Gas Producers
PPE Personal protective equipment
Sievert Sievert (Sv) is the SI unit of measurement of radiation dose uptake

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4 What is NORM?
All rocks contain small amounts of radioactive material. Some of this radioactive material may be dissolved
with various salts found within water in the rock formations and brought to the surface in produced water.
It is also possible for produced gas to be mildly radioactive due to gaseous entrainment of the decay products
of radon gas. Any surface that comes into contact with well fluids can, potentially, become contaminated with
NORM (naturally occurring radioactive material).
NORM may also occur as scale, sludge or sand derived from pipework and other process vessels used on oil
and gas installations.
It should be noted that radioactivity is present to a greater or lesser extent throughout everything we use in
our everyday lives. This naturally occurring radioactivity is present in food, air, building materials etc. and
contributes to our normal background radiation dose. Many governments impose regulations regarding the
concentration of radioactivity encountered at work, whether natural or man-made, which stipulate that
precautions should be taken to prevent ingestion, inhalation and contamination.
Members should consult appropriate radiation specialists with regard to the regulatory and practical definition
of radioactive contamination in their specific area of operations.
Procedures for working with NORM are designed to prevent the accidental inhalation and ingestion of NORM.
This is achieved by making sure that, whenever possible, NORM is contained inside suitable containers, that
work involving NORM is carried out by properly equipped and trained people in a suitable area and the people
involved in the work practice good standards of hygiene and housekeeping. In most circumstances, personal
protective equipment is worn to minimise the risk of NORM being ingested or inhaled.
4.1 The Production of NORM
The changes in pressure and temperature undergone by produced water during co-production with
oil may, under certain circumstances, cause the deposition of scale within the oil production and
processing systems. This is a very simple explanation of what is in practice a very complex chemical
process. Different processes cause NORM to be deposited in the pipework of installations producing
gas and condensates. These deposits, referred to as sulphates, are deposited within offshore systems
in a layer known as ‘scale’. These types of oilfield scales are naturally radioactive and are known as
NORM (low specific activity) scales. They are generally a hard, greyish, insoluble scale found in pipes
and elsewhere, which can contain measurable quantities of naturally occurring radio-isotopes. The
radio-isotopes cannot be seen and can also be mixed with any inert material such as sand, sludge and
other deposits.
NORM scale may also be encountered during operations where pipework is opened or when
production fluids are released or discharged from a platform, as during decommissioning, pipe
removal, asset removal and choke insert replacement.
4.2 What is the Risk to Health of NORM?
The effects of radiation on people are well understood. A large radiation dose can result in harmful
effects, even death, in exceptional circumstances.
Large radiation doses are very unusual and are unlikely to occur even under accident conditions.
There is no possibility of anyone working with NORM receiving doses that could cause any health
effects in the short term. Working with NORM will not cause sickness, nor can it cause coughs,
rashes or burns.
The risks involved in working with NORM are very low when compared with other every day risks.
However, it is sensible to reduce any risk and it is for this reason that the safety measures involved in
working with NORM are implemented and radiation doses are maintained ‘as low as reasonably
practicable’.
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4.3 Other Forms of Radioactive Material Encountered in the Oil & Gas Industry
4.3.1 Sea Water Pumping and Injection Equipment
Seawater also contains NORM at very low concentrations. Over periods of years, seawater
pumping and injection equipment will be exposed to massive volumes of seawater. Under
some conditions of pressure, temperature and particularly the surface state of the metals, this
type of equipment may become contaminated with very thin NORM deposits.
4.3.2 Artificial Radioactive Sources
Relatively high activity radioactive sources are often used on offshore installations for
radiography and for well logging work. These sources are physically quite small and the
radioactivity is sealed inside welded stainless steel capsules. The hazard from this type of
radioactive source is radiation being emitted by the source. When the source is correctly
housed in its container the hazard is reduced because the container shields much of the
radiation being emitted by the source.
The controls implemented in working with these types of radioactive sources aim to limit
exposure by either shielding the source, by keeping people away from the source or by
restricting the time people can spend near the source.

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5 Identifying Radiological Hazard
NORM generally contains Radium-226, Radium-228 and associated daughter isotopes. However, deposits from
oil production can take different forms both in chemical and isotopic content. The form of material
encountered has implications for identification and measurement. When radioactive isotopes decay, radiation
is emitted. However, it should be stressed that the radiation emitted from NORM is very low.
There are two main routes of exposure to the radiological hazard from NORM. These are:
♦ Ingestion – where radioactive material is carried into someone’s digestive system;
♦ Inhalation – breathing radioactive material into the lungs.
NORM scale is considered hazardous as it can be inhaled or ingested. If NORM contaminated materials
become dry, they may give rise to airborne dust which could collect in the lungs. Procedures should be in
place which will minimise the likelihood of inhalation, whilst also minimising the risk of exposure from other
routes of entry.
6 Considerations for Operational Planning
6.1 Risk Assessment
For the purpose of risk assessment, IMCA members’ primary activities involving NORM can be divided
into three categories:
♦ Diving involving NORM contaminated equipment;
♦ Recovery of NORM contaminated equipment;
♦ Disposal of NORM contaminated equipment.
6.1.1 Diving Involving NORM Contaminated Equipment
The main hazard faced, albeit minimal, is that of possible spreading of contamination from the
diving bell into hyperbaric living quarters. The risk of contamination is controlled through
procedures and training, the use of radiation monitors, proper NORM handling equipment
and personal protective equipment (PPE) and, where necessary, the appropriate washing of
contaminated equipment by a method that will not contaminate drains or other equipment,
and careful disposal of waste in accordance with appropriate procedures.
6.1.2 Recovery of NORM Contaminated Equipment
The main hazards faced are the spillage of NORM during recovery operations and the risk of
spreading the contaminated material which could result in inhalation or ingestion. These risks
are controlled through proper training, procedures, appropriate handling equipment and PPE,
the use of radiation monitors, the use of suitable lined half-height containers, and in-sea (or
over-the-sea) drainage of recovered equipment.
6.1.3 Disposal of NORM Contaminated Equipment
The main hazard is the inappropriate disposal of contaminated equipment, leading to
contamination of the disposal location. There may be non-compliance with regulatory
requirements which could result in subsequent possible prosecution. It is mitigated by
following any local regulatory procedures which could include confirmation that disposal
authorisation is in place, identification and agreement of disposal route with the receiving
body and that dangerous goods transportation is provided by the client or duty holder.
6.2 Operation of Radiation Monitors and Other Detection Equipment
Radiation monitoring underpins safe working practices when dealing with radioactive materials.
Radiation monitors can be used to assess dose rates and surface contamination.
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Many monitoring instruments use detectors based on the ionisation of a gas. The absorption of
radiation in a gas results in the production of ion pairs and this flow of ions generates a small electric
current which is a measure of the radiation intensity in the gas.
Other monitors utilise the emission of light (scintillation) from the detector that is then converted to
electric current which is a measure of the radiation detected.
In all cases the contamination monitor chosen should have been tested and calibrated for the
detection of NORM.
6.2.1 Contamination Monitors
Contamination monitors are used to identify the presence of NORM and to determine the
levels of contamination on surfaces in terms of the number of Becquerels per square
centimetre of surface (Bqcm
-2
).
The appropriate monitor to use in any given situation will depend on the nature of the
NORM, whether scale based from oil production operations involving Radium-226 and 228
or from gas operations where the predominant isotope will probably be Lead-210 and its
daughters. Advice should be sought from an appropriately trained radiation protection
adviser as to which instrument is best suited for the particular application.
6.2.2 Contamination Monitoring Before, During and After Work
It is important to be vigilant while working with NORM and contamination monitoring should
take place before, during and after such work. This will require the use of calibrated
monitoring equipment to measure potential contamination. The use of such monitoring
equipment should be restricted to individuals who are competent in its use. Additionally, it is
good practice to record time spent whilst working with NORM.
6.3 Training and Awareness
It is important that people handing NORM scale are adequately trained and are fully aware of the
hazards associated with NORM, the controls that are required for their protection and the methods
for preventing environmental contamination.
Training should focus on operational personnel who are potentially exposed to NORM and directly
involved in maintenance operations. Key personnel should be identified and provided with training so
that they are aware of the hazards of working with NORM and that they undertake their work to
ensure that they prevent the spread of NORM contamination.
Further information on training and awareness can be found in the OGP document – Guidelines for the
management of naturally occurring radioactive material (NORM) in the oil & gas industry – OGP 412.

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7 Guidelines for Operational Activities when Handling NORM
The responsibility for NORM materials remains with the authorisation or duty holder operating the offshore
facility from which the material has been derived (generally, this is the client). It is important to ensure that the
client remains responsible and accountable for radioactive materials.
The primary role of the contractor is to ‘bag and tag’ components for further processing by the duty holder.
This could involve securing, blanking or ‘double-bagging’ of pipeline ends and other materials including the use
of properly sealed and marked (with radiation transport labelling) ‘half-height’ containers.
A typical flow chart for the handling of potentially contaminated equipment or materials is found at Appendix 2.
7.1 Control of Exposure
The most effective protection from exposure to radiation is summarised by ‘ABC’:
♦ Away – as far as possible, keep your distance;
♦ Barriers and shielding – including air space, skin, clothing and any physical barriers, and keeping
material ‘damped down’ as necessary;
♦ Clock time – the shorter the time spent with or near radioactive materials, the lower the risk.
Procedures and suitable checklists will also be a useful tool in the control of exposure. Some sample
checklists can be found in the appendices.
7.2 Contingency
The following are some hazards associated with NORM which should be considered when developing
appropriate contingency plans.
7.2.1 Over-Exposure
It is highly unlikely that any activities involving work with NORM will give rise to external
radiation doses such that an exposed person will exceed any relevant dose limit.
7.2.2 Physical Injury to a Person Contaminated with NORM
The principle to be followed is that any injury to a contaminated person should always take
precedence over exposure, since the real risks of exposure are insignificant compared to the
risks arising from not properly treating an injury.
7.2.3 Spillage of NORM
All reasonably practical measures should be taken to prevent further release or spillage, and
to contain material that has already been released. An assessment of surface contamination
should be conducted using appropriate monitors, and any physical barrier arranged to
prevent access to the area and spread of contamination.
7.2.4 Loss and Unauthorised Disposal of NORM
In general, loss and unauthorised disposal of NORM should be reported to the appropriate
company official so that reports can be prepared for the relevant authorities.
7.3 Preparation, Precautions and Decontamination
7.3.1 PPE and Other Essentials
The main principle is that if PPE can be treated or washed such that it can be monitored as
being at background, then safely re-used, then the use of such PPE is appropriate. The re-use
of PPE is appropriate provided that it can be appropriately treated or washed, and a
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contamination monitor is used to check that the PPE is only exhibiting a background level of
radiation.
7.3.2 Decontamination
Cleaning or decontamination of material contaminated with NORM should follow company
specific procedures and be carefully controlled to avoid further spread of contamination.
Some of the issues to consider are as follows:
 Contaminated PPE should not be placed in a washing machine or sink;
 Contaminated PPE should be decontaminated using a container that allows retention of
the water and contamination residue for disposal by a route that will not contaminate
any of the ship’s systems. If decontamination is not possible, the PPE should be placed in
double bags, sealed and held for controlled disposal;
 To ensure contamination is not being transferred, care and attention is needed when
checking over-suits, dive suits and other tools or equipment;
 Particular care may be needed in checking the knee and arm areas of diving suits;
 Washing down the deck and other areas that may have been contaminated is also good
practice.
7.4 Divers
During saturation diving operations, the potential exists for radioactive material contained in drill
cuttings and mud deposits to become stirred up by divers. The diver inside the suit is not at risk
during actual diving, but the personal equipment used – the suits and boots, harness, helmet and
umbilical – may be exposed to low level contamination from radioactive materials stirred up
underwater.
Within a diving bell there is generally 100% humidity; it is unlikely that dust will form from material
deposited on suits, boots and other equipment.
7.4.1 Equipment Connection/Diver Operation Subsea
Good bell positioning will reduce the potential of bell contamination in the event of leakage
or downline failure.
Diver involvement will generally be limited to downline connection/disconnection to subsea
assets. Care should be taken to ensure downlines are connected prior to being charged and
thoroughly flushed prior to disconnection. Divers should be removed from the area prior to
leak/pressure testing of equipment, thus reducing the potential for contamination of divers
and their living spaces. Appropriate procedures should be in place to reduce the potential
for contamination.
If divers are working with NORM, the following should be taken into account:
 Open cuts should be covered with waterproof dressings and further protected from
contamination;
 Diver over-suits should be made of a washable material, to reduce the potential for
contaminated waste, and worn over the diver’s hot water suit;
 Wellington boots should be without holes;
 Surgical type gloves worn under heavy duty PVC/rubber gloves, again, without holes;
 Umbilicals should be protected with washable material if likely to be used in a potentially
contaminated area;
 Before entering the bell it may be appropriate to clean PPE/equipment using scrubbing
brushes and liquid detergent.
Divers working on old (earlier than 1994) wellheads may need to exercise caution as there
could be layers of radioactive material in the older oil-based drilling muds. A full treatment of

IMCA SEL 024 9
this is beyond the scope of this document. IMCA Diving Division has already published a
number of documents containing guidance on radioactive materials, including the following:
 IMCA D 021 – Diving in contaminated waters;
 IMCA D 022 – The diving supervisor’s manual.
It should be emphasised that where procedures are followed, the potential for diver
contamination is low. Good hygiene practice will further prevent the risk of contamination
transfer to the bell/hyperbaric system.
Currently, monitoring equipment is not designed to operate within hyperbaric systems,
therefore, thorough diver decontamination and post dive-equipment monitoring should be
completed prior to the divers transferring to their living chambers.
7.5 Transportation of NORM to the Decontamination Contractor
It is important that great care is taken to ensure that NORM material is properly packaged and
labelled. NORM should not be transported loose and should be segregated at all times from other
materials and items. The receiving facility and the carrier(s) should be notified with full details of the
consignment, including description, weight, size and sealing/marking arrangements.
Any movement of NORM across national frontiers will need careful planning and preparation to deal
with the various regulatory bodies involved. Reference should be made to local and international
legislation covering the transport of dangerous goods.
7.5.1 Offloading NORM in Port
The following steps are recommended when NORM contaminated material is offloaded in
port.
 Inform the port authorities;
 Confirm that material remains properly sealed and labelled;
 Any damage to sealing materials should be repaired, but a documented risk assessment
should be carried out to determine if this can be safely carried out;
 Stow materials in an appropriate transport container;
 Advise the receiving facility/carrier of the NORM contaminated (and crude oil
contaminated) materials, including full details of description, size, weight and
sealing/marking arrangement;
 Advise transport company/registered carrier and issue appropriate documentation.
7.5.2 Dangerous Goods Transportation (ADR)
The ADR agreement (Accord Européen relatif au transport international des marchandises
dangereuses par route) allows dangerous goods travelling by road through more than one
European Union country to be exempt from the domestic legislation in force in those
countries, provided the requirements of ADR are met in full.
7.5.3 The International Maritime Dangerous Goods Code (IMDG)
The IMDG Code contains internationally agreed guidance on the safe transport of dangerous
goods by sea and most commonly relates to the carriage of dangerous goods in freight and
tank containers. Individual countries are responsible for implementing the code under their
own legislative framework.
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8 Regulatory Framework
The regulatory framework for management of radioactive material differs from country to country and can
have a significant impact on members’ business, particularly if it is not fully understood. Dialogue and
engagement with regulatory agencies is worthwhile and necessary to ensure a practical and proportionate
approach to regulation of NORM handling and disposal. Without this close dialogue there is the risk of
inappropriate criteria being applied to members’ work, with consequent commercial impact.

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Appendix 1
Typical NORM/LSA Checklists

Checklist – Preparing for Recovery Tick
Above named to read the task procedure
Task risk assessment conducted
Above named to read task risk assessment
Radiation protection specialist identified
If radiation protection specialist required, radiation protection specialist identified and provided
Radiation protection specialist aware of task procedure and task risk assessment
Radiation protection specialist prepared for testing of material on deck
Appropriate monitoring equipment available (with valid certificate)
Background counts taken:
........................................................................................ (add average count here)

Suitable landing area identified:
........................................................................................ (add location here)

Suitable storage area or container identified and designated
Suitable and sufficient plastic sealing material, tape and markers available
Radiation protection specialist to brief deck crew on risks from NORM/LSA scale and precautions to prevent
exposure

Radiation protection specialist to brief deck crew of the area for handling the component/s
Works planned to ensure number of personnel approaching the component is minimised
Deck crew wearing appropriate PPE
Visual check conducted to identify persons with open wounds. All wounds to be dressed and within PPE
Visual check conducted to ensure no smoking/drinking/eating (including chewing gum, sweets or tobacco)
Deploy selected rigging
Ensure that seawater can drain overboard from the component during recovery and will not flow across deck

Checklist – Recovery and Storage
Tick
Ensure that deck crew continue to wear the appropriate PPE and refrain from eating and smoking in the area
Radiation protection specialist measured level(s) of radioactivity
If all recovered components are found to be non-contaminated do not continue to fill out this form. File as
appropriate and ensure that crew are informed.

Component/s marked either contaminated or checked and found not to be contaminated
Component/s sealed as appropriate
Component/s secured
Deck washed down after component is sealed
Tables below filled in for each component
Area control requirements identified and implemented
Radiation protection specialist to inform crew of level of designation and requirements of that area, e.g.,
supervised areas require entry logging but do not require PPE once the item is bagged

Dangerous goods requirements for sea transport (or air if going by helicopter) conducted by competent
person:
Marking
Labelling
Documentation (dangerous goods note)


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Appendix 2
Handling of Potentially NORM Contaminated Equipment
Identification through risk assessment that
NORM scale may be present in equipment
being recovered from well or subsea
Set up landing area (covered in polythene)
on surface to minimise contaminated
spread
Allow item to free drain prior to landing
Place item in landing and monitor
contamination against background
Surface contamination exceeds
background
Set up supervised area
Conduct risk assessment
Control personnel, equipment movement
and contamination
Work in accordance with company
NORM procedures and regulatory
requirements. Re-assess if heavily
contaminated
Contaminated equipment is bagged and
tagged ready for transport onshore
Area decontaminated to background
All decontaminated materials and
equipment handled as relevant
Records updated and arrangements for
contaminated equipment or shipment
onshore
Surface contamination background or
below
Record readings in log
Item is not NORM contaminated and can
be handled normally
All contaminated materials and equipment
handled as required by relevant guidance
Refer to contingency arrangements in
NORM procedure
Emergency during NORM scale
operations
Personnel and PPE decontaminated to
background