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
QUESTIONS?