NORM MANAGEMENT IN THE OILFIELD “We have solutions for your NORM problems” N “We have solutions for your NORM problems” S O L U T I O N S R Geri Cooley, MS, REM, CSP Radiation Safety Officer M NORM MANAGEMENT IN THE OILFIELD PERMIAN BASIN STEPS NETWORK MAY 11, 2010

WHY DO COMPANIES DECON EQUIPMENT? Avoid Pollution Maximize Storage Capability Comply With Regulations Protect Workers Property Transfers Continue Operations

TEXAS AGENCIES Railroad Commission of Texas Disposal Only of Oil & Gas NORM Department of State Health Services Possession, Handling, Worker Protection, Transportation EVERYTHING UP TO DISPOSAL Department of Transportation Transportation of Radioactive Material

LICENSEE CATEGORIES 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. Is it Routine Maintenance or Decontamination?

NORM SPECIFIC LICENSEES IN TEXAS Aecom Technical Services Inc Alamo Environmental Inc Almac LLC Dunagin Transport Co Enercon Services Inc Etech Environmental & Safety Solutions Four Lane Inc Lighthouse Environmental Services Lotus LLC Newpark Environmental Services LLC NORM Decon Services LLC Nuclear Sources & Services Inc Protechnics Environmental PSC Industrial Outsourcing LP Radiation Environmental Mgmt SYMB Environmental LLC United States Environmental SVCS US Ecology Texas LP USA Environment LP Reciprocity Licensees: American Pollution Control Corp – LA Dade Moeller And Associates Inc – MD Dynamic Industries Inc – LA Energy Solutions LLC – TN Grand Isle Shipyard – LA Major Equipment & Remediation Svcs – LA Rice Operating Company – NM Trussco Inc – LA

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 4.605 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, man way, etc.)

SURVEY 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 form with a schematic of the site Take Pictures

EQUIPMENT & WASTE Vessels/Pipe are Contaminated at 50 µR/hr Determines if a specific licensee is required to decon the vessel Waste/Soil is contaminated at 30 pCi/g of Ra226 & Ra228 or 150 pCi/g of the associated daughter products (Pb210) Waste Characterization Disposal

RADIATION UNITS Exposure – Radiation that is emitted from an object Roentgen – Measures Exposure (R/hr) Exposure – Radiation that is emitted from an object REM – Measures Dose Dose – Radiation that contacts the body RAD – Measures Absorbed Dose Absorbed Dose – Radiation that enters the body and can cause damage

SHIPPING SAMPLES DO NOT SHIP SAMPLES VIA THE U.S. POSTAL SYSTEM! It is illegal to ship radioactive material USPS Use a Private Carrier (FEDEX, UPS, DHL, etc) Packages that measure over 50 µR/hr require: “UN2910” must be written on the inside package The outer package must not exceed 500 µR/hr

NORM TRANSPORT Determine if the load is considered “Radioactive” per DOT – 2 steps 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 If Radioactive, survey outer package > 500 µR/hr then placard “Radioactive” and manifest with proper shipping name

AUTHORIZED DISPOSAL 16 TAC RULE 4.614 Authorized by Rule Disposal in plugged & abandoned wells Burial At the Same Site where the NORM was generated Land farming At the Same Site where NORM was Generated Disposal at a licensed facility Injection If NOW Waste Permit Required Non-retrieved Flowlines/Pipelines Commercial Surface Waste Management Facilities Disposal into plugged & abandoned wells Injection into Enhanced Oil Recovery Injection Wells Injection

NORM COMMERCIAL DISPOSAL FACILITIES All Facilities use injection disposal methods New Park Resources – Winnie TX Inject Into Domal Salt MB Energy – Liberty TX Lotus LLC – Andrews TX Salt Cavern Disposal Into Bedded Salt

Geri Cooley, MS, REM, CSP Radiation Safety Officer “We have solutions for your NORM problems” N “We have solutions for your NORM problems” S O L U T I O N S R Geri Cooley, MS, REM, CSP Radiation Safety Officer M QUESTIONS? Office: (432) 847-9698 Fax: (432) 355-4404 gcooley@normsolutions.com www.normsolutions.com