Transcript Document
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 misunderstandin g • Issue developed in the 1980s & 1990s • Ra226, Ra228, Rn222, & daughter products WHO REGULATES NORM? • Railroad Commission of Texas • • Department of State Health Services • • Disposal Only of Oil & Gas NORM Possession, Handling, Worker Protection,Transport ation, etc. – EVERYTHING UP TO DISPOSAL! Department of Transportation • Transportation of Radioactive Material SPECIFIC LICENSEE / GENERAL LICENSEE • • • General Licensee - Producers, operators, equip ment yards, pipe yards, etc. Specific Licensee - A company that applies to an d is approved by the regulatory authority for a l icense 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 & si RRC MARKING RULE 16 TAC Rule 4.601 • • • All Operators/Producers in Texas MUST mark the ir NORM-Contaminated Equipment with the letter s “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 requi red 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” p er DOT – 2 steps 1. Rule of Thumb Calculation - Gamma Spectroscopy • • • • 2. Ra226 % = Analysis / 2,700 pCi/g Ra228 % = Analysis / 2,700 pCi/g Th228 % = Analysis / 270 pCi/g Total % > 100% Radioactive, < 100% Non-radioactive If Radioactive, survey external package > 500 µR/hr t hen placard “Radioactive” and manifest with prop er shipping name AUTHORIZED DISPOSAL METHODS Authorized by Rule • • • • • Disposal in plugged & abando ned 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/Pipeline s Commercial or Centralized Surfa ce Waste Management Facilities Disposal in plugged & abandone d wells Injection Injection in Enhanced Oil Recove ry Injection Wells QUESTIONS? Geri Cooley, MS, REM, CSP Regulatory Affairs & HES Manager/ Corporate RSO 888-414-3320 ofc 432-524-4993 fax [email protected] www.lotusllc.com