Hello Farid,
Good documents shared, thanks for your question and to contributors.
One point may be added, though obvious: risk-assess the need to RIH such source versus the LIH risk. Geosciences will understand if drillers present to them a fair risk-analysis concluding not to do so.
Not all such sources can be fished unfortunately (i.e; LWD with bolted/anchored sensors barrels into its drill collar). Although the source is encapsulated, fitted withing an instrumented barrel and protected by the surrounding DC wall thickness, in the long term, in a corrosive HC reservoir environment, leaks could occur, therefore no one would take the risk of compromising the whole field production. If LIH across an aquifer, even deep, but onshore, say in Europe with dense population and large regional aquifers, no one would take the LIH risk, the situation being different offshore far away from shore. Even a retrievable LWD RA source could be challenging to fish, i.e. in a horizontal drain, special tools and competent people are required, but you will hardly find LWD engineers with RA source fishing experience (RA source LIH is rare fortunately). Though Risk Assessment case by case is of essence.
With regards to NORMS, it is an extremely expensive business to deal with and no way around regulation (derogation) in some EU countries. It can be a nightmare when P&A if budget isn't provisioned for it. Some EU country regulation would require treating every tubular joints in special solutions in dedicated premises, and conditioning the RA waste solution in drums and storing in dedicated locations for long term, as well as for treated tubular. It seems to me a significantly increased risk of exposure during the treatment process and in the long term. Coil Tubing wash & squeeze, if workable (case by case), flushing the NORMS back into the reservoir where it comes from may be much cheaper but not always a regulatory option (neither a technical option in some case and if the P&A operation may be put a stake by doing so).
Regards
Régis