Factsheet SARU ash
LM van Langen
Version 1.0
November 28, 2024


1. Description of the material
General
Rest stream from crude oil refining. It is a concentrate of metals present in crude oil. This rest steam underwent a high temperature treatment that removed all hydrocarbons, leaving a dry finely powdered ash.

Chemical
Mixture of sodium metavanadate, trinatriumorthovanadate and nickel oxide
SDS available

Radiochemical
Rest stream with naturally occurring radionuclides

Test report gammaspectrometry available


Description of the intended use of the ash
Selective hydrometallurgical extraction of vanadium using lye
Total amount of processed ash: ≤60 kg ash
Batch scale: 3.5 kg of ash
Duration of the campaign: ≤3 months

Actions according to the NL law:
Besluit basisveiligheidsnormen stralingsbescherming
[wetten.nl - Regeling - Besluit basisveiligheidsnormen stralingsbescherming - BWBR0040179]

2.2. Justification 	
Article 2.2. (justification, general)
The following acts and measures must be justified prior to their implementation:
(a) Actions in planned exposure situations;

[See section 3.2] Our <1000 kg  operation is regarded intrinsic safe (see Appendix 3A3a), if the type of handling can be justified.
Our handling can be justified by:
The handling takes place under controlled process conditions
The radionuclides remain in the solid fraction after the extraction
The handling provides valuable knowledge about the valorisation of this rest stream for Society.

I suggest to formulate this justification in the RI&E


3.2 Permit, registration or notification
3.17 
Section 3.2 does not apply to operations within a site with radioactive materials:
C:
in the case of operations in moderate quantities, up to 1 000 kg, of any type of material in which the concentration of activity of the radionuclides in the radioactive substance concerned does not exceed the  exemption values set out in Annex 3, Section B, Table B, column 2. 
Values taken from Annex 3, Section B, Table B, column 2.

Conclusion: for processing the ash at the scale of the demo, section 3.2 does not apply. 

3.3.2. Resource release
Article 3.20. (release, radioactive materials)	
Section 3.2 does not apply to operations with radioactive materials intended for disposal, recycling, reuse or incineration:
 the concentration of activity of the radionuclides in the radioactive substance concerned does not exceed:
2°.the relevant release value for naturally occurring radionuclides set out in Annex 3, part B, Table A, Part 2, or
Values taken from Annex 3, Section B, Table A, part 2.

My conclusion is that we need a notification to dispose of our ‘waste’ material as the activity concentration of the U-238 series is >1 KBq/kg (Bq/g).
Special attention to Annex 3, Section B, Table B, column 3, that states the release value for the total amount of a radionuclide
Values taken from Annex 3, Section B, Table B, column 2.

These values correspond to ca 3.5 kgs of ash (limited by the Pb-210 and Ra-228 quantities) that can be disposed of. 
This is relevant for the ash that will end up in the chemical waste stream from the demo. This is either solid waste, consisting on papers that wiped ash rests or suspended ash particles in liquid waste.

I suggest to formulate in the RI&E how we will dispose of the residue, and that we estimate the absolute amount of ash that we will dispose of in the normal  chemical solid waste.

Article 4.2. (administration and files sources)	
1 An entrepreneur shall keep records of all sources for which he is responsible in which at least data are kept relating to:
a. the type, nature and location of the source;
b.de manner of its application, and
c.de means of transferring the resource or discarding it after cessation of use.
2The entrepreneur who carries out transactions with the source shall keep records of those transactions.
3The administration and files as referred to in the first and second paragraphs shall be housed in a management system.
4The records shall contain at least:
a.de name of the legal entity and of the responsible radiation protection expert and supervisory radiation protection officer;
b.de place where the transactions are carried out;
c. a description of the nature and scope of the acts; and
d.de assessment of the risks referred to in Article 7.1.

5 Further rules may be laid down by regulation of the Authority on the implementation of paragraphs 1 to 4, including the retention periods of the administration and the files.

I conclude that we are not exempt from having this administration
I suggest that we describe the administration, mentioned above, in our RI&E.


Article 4.4. (general obligations of entrepreneurs)
1 The entrepreneur shall, after consultation with a radiation protection expert or radiation protection supervisor, determine measures to prevent damage and ensure that they are carried out.
4 The entrepreneur shall ensure that wells are protected against fire as far as reasonably possible.

I think these items above should be addressed in the RI&E

4.3.1. General
Article 4.6. (storage of radioactive substances)
 1 The entrepreneur shall ensure that when open and sealed sources are not used, they are stored in a suitable storage place.
Article 4.7. (protection of radioactive substances)
 1 In cases belonging to a category designated by regulation of the Minister, the entrepreneur shall provide a security plan describing the provisions made with regard to the security of a source.
I think these items above should be addressed in the RI&E


§ 4.3.4. Open sources
 
Article 4.20. (contamination control rooms; open source operations)
1 The entrepreneur shall ensure that areas and places where operations are carried out with open sources, the arrangement thereof or articles used therein, are regularly checked for contamination in accordance with procedures established by him in writing on the basis of international standards.
We have to justify on the basis of the intrinsic safety of our demo process (<1000 kg), and our process control measures, that contamination control is not needed

Article 5.7. (supervisory radiation protection officer)
The entrepreneur who carries out or has carried out an action that entails or may cause occupational exposure or exposure of a member of the public shall ensure that this action is carried out by or under the supervision of a supervisory radiation protection officer.
See also article 7.1: advisable to build the  structure with a radiation protection expert.
For the laboratory permit for using the x-ray diffraction analyzer, we contacted SBD Van Driel BV - 
This expert can corroborate certain statement that we make in the RI&E

Article 6.3. (reports sources)
1  The entrepreneur shall immediately report the following events and measures to the Authority:
(a) a loss, theft or significant leakage from a source that results or may result in an exposure that should not be neglected, or unauthorised use or the unintended dissemination of that source;
b. the measures taken following a loss, theft, significant leakage, unauthorised use or unintentional distribution as referred to under a or any event in which a source may have been damaged.

I think this should be addressed somewhere in our RI&E

§ 7.1.1. Obligations of the entrepreneur
 
 
Article 7.1. (supervision and consultation of the radiation protection expert)
The employer is obliged, with a view to protecting workers and members of the public against ionizing radiation, to have the radiation protection expert carry out supervision or to consult him and makes available to him the means necessary to be able to perform his duties properly.
See also article 5.7: advisable to build the  structure with a radiation protection expert.
For the laboratory permit for using the x-ray diffraction analyzer, we contacted SBD Van Driel BV - 
This expert can corroborate certain statement that we make in the RI&E


Article 7.3. (exposure of workers, general)
One of the statements, as mentioned above, is that the scale of the demo can be regarded as intrinsically safe (Annex 3, A3b); a corroboration by the expert would be valuable here.

Article 7.6. (further requirements for risk inventory and evaluation)
1 The employer shall ensure that, in the context of the risk inventory and evaluation referred to in Article 5 of the Working Conditions Act, the assessment of the risks and all other findings of the radiation protection expert with regard to the subjects referred to in Article 7.1, second, third and fifth paragraphs, insofar as they concern the safety and health of the employees,  are included and recorded.
See previous

Article 7.7. (zones)
Chapter 9. Exposure of members of the public
One of the statements, as mentioned above, is that the scale of the demo can be regarded as intrinsically safe (Annex 3, A3b); a corroboration by the expert would be valuable here.


§ 10.2. Discarding radioactive waste 
Article 10.2. (duty of care entrepreneur)
1 The entrepreneur who performs an action shall ensure that, as far as reasonably possible:
a. the generation of radioactive waste and the discharge of radioactive substances is prevented or reduced,
b. sources are reused as such after use,
(c) radioactive substances and materials constituting a source are reused after their use, or
This should be addressed in the RI&E


Article 10.7. (designating radioactive substance as waste)
1 A radioactive substance may be regarded as radioactive waste by the Authority or the entrepreneur if no use or product or material reuse is foreseen for this substance by the Authority or by the entrepreneur and there is no discharge of the substance.
2 Waste shall not be regarded as radioactive waste if the activity concentration of that waste is lower than the relevant release value determined by or pursuant to Article 3.20 or 3.21 and Article 10.6(1) applies.
3 Radioactive waste shall be disposed of as soon as reasonably practicable, but in any event within a period set by the Authority.
The residual ash after extraction has to be defined as waste in case we will not process it further in this demo.


Origin | Nuclide | Activity Bq/g
U-238 decay chain | U-238+ (Th-234)
Ra-226+ (Pb-214)
Pb-210+(Pb-210) | 0.07 ± 0.02
0.32 ± 0.03
2.42 ± 0.21
Th-232 decay chain | Ra-228+ (Ac-228)
Th-228+ (Tl-208) | 0.27 ± 0.03
0.18 ± 0.02
Other nuclides | K-40
U-235 | ≤0.05 (detection limit)
≤0.05 (detection limit)
Nuclide | Bq/g
U-238 | 10
Ra-226 | 10
Pb-210 | 10
Ra-228 | 10
Th-228 | 1
K-40 | 100
U-235 | 10
Natural radionuclide | Bq/g
Decay series U-238 | 1
Decay series U-235 | 1
Decay series Th-232 | 1
K-40 | 10
Nuclide | Bq
U-238 | 1∙104
Ra-226 | 1∙104
Pb-210 | 1∙104
Ra-228 | 1∙103
Th-228 | 1∙104
K-40 | 1∙106
U-235 | 1∙104