norm management in the oilfield geri cooley, ms, rem, csp lotus, llc permian basin steps network...
TRANSCRIPT
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?