NORM MANAGEMENT IN THE OILFIELD Geri Cooley, MS, REM, CSP Lotus, LLC Permian Basin STEPS Network...

NORM MANAGEMENT IN THE OILFIELD

Geri Cooley, MS, REM, CSP

Lotus, LLC

Permian Basin STEPS Network

October 14, 2008

INTRODUCTION TO NORM

• Gaining notice by litigation and public misunderstanding

• Issue developed in the 1980s & 1990s

• Ra226, Ra228, Rn222, & daughter products

WHO REGULATES NORM?

• Railroad Commission of Texas • Disposal Only of Oil & Gas NORM

• Department of State Health Services• Possession, Handling, Worker

Protection,Transportation, etc. – EVERYTHING UP TO DISPOSAL!

• Department of Transportation• Transportation of Radioactive Material

SPECIFIC LICENSEE / GENERAL LICENSEE

• General Licensee - Producers, operators, equipment yards, pipe yards, etc.

• Specific Licensee - A company that applies to and is approved by the regulatory authority for a license to perform NORM work.

• The Gray Area – Is it Routine Maintenance or Decontamination?

HANDLING NORM

• General Licensee – Required to have a NORM Worker Protection Plan; 25 TAC 289.202

• Worker Protection Worker Training – get trained!• NORM Awareness• NORM Worker• NORM Surveyor• Radiation Safety Officer (RSO)

• Secure the location/equipment with notices & signs

RRC MARKING RULE 16 TAC Rule 4.601

• All Operators/Producers in Texas MUST mark their NORM-Contaminated Equipment with the letters “NORM”

• Clearly visible waterproof tag or marking with a legible waterproof paint or ink

• Must be conspicuous to the worker (by the valve, manway, etc.)

SURVEYING TECHNIQUES

• Survey within 1 centimeter of the surface• Check the response of the meter every

time you conduct a survey• Meters must be calibrated every 12

months• Record the results of the survey on a

report or a form with a drawing of the location

• Take Pictures of the Location

EQUIPMENT VS. WASTE

• Vessels/Pipe are Contaminated at 50 µR/hr – • Reading on the equipment determines if a specific

license is required to re-mediate the vessel• Waste/Soil is contaminated at 30 pCi/g of Ra226 &

Ra228 or 150 pCi/g of their daughter products –

• The activity level of the waste determines how the waste must be disposed

TRANSPORTATION OF NORM

• Determine if the load is considered “Radioactive” per DOT – 2 steps

1. Rule of Thumb Calculation - Gamma Spectroscopy• Ra226 % = Analysis / 2,700 pCi/g• Ra228 % = Analysis / 2,700 pCi/g• Th228 % = Analysis / 270 pCi/g• Total % > 100% Radioactive, < 100% Non-

radioactive

2. If Radioactive, survey external package > 500 µR/hr then placard “Radioactive” and manifest with proper shipping name

AUTHORIZED DISPOSAL METHODS

Authorized by Rule• Disposal in plugged &

abandoned wells• Burial (at the same site

where the NORM was generated)

• Land farming (the same site where NORM was generated)

• Disposal at a licensed facility

• Injection (if waste is NOW)

Permit Required• Non-retrieved

Flowlines/Pipelines• Commercial or Centralized

Surface Waste Management Facilities

• Disposal in plugged & abandoned wells

• Injection• Injection in Enhanced Oil

Recovery Injection Wells

Geri Cooley, MS, REM, CSPRegulatory Affairs & HES Manager/

Corporate RSO

888-414-3320 ofc432-524-4993 fax

gcooley@lotusllc.comwww.lotusllc.com

QUESTIONS?