1. NORM MANAGEMENT IN THE OILFIELD Geri Cooley, MS, REM, CSP Lotus, LLC Permian Basin STEPS Network October 14, 2008

2. INTRODUCTION TO NORM Gaining notice by litigation and public misunderstandin g Issue developed in the 1980s & 1990s Ra 226, Ra 228, Rn 222, & daughter products

3. WHO REGULATES NORM? Railroad Commission of Texas Disposal Only of Oil & Gas NORM Department of State Health Services Possession, Handling, Worker Protection,Transport ation, etc. – EVERYTHING UP TO DISPOSAL! Department of Transportation Transportation of Radioactive Material

4. SPECIFIC LICENSEE / GENERAL LICENSEE General Licensee - Producers, operators, equip ment yards, pipe yards, etc. Specific Licensee - A company that applies to a nd is approved by the regulatory authority for a license to perform NORM work. The Gray Area – Is it Routine Maintenance or Decontamination?

5. 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 gns

6. RRC MARKING RULE 16 TAC Rule 4.601 All Operators/Producers in Texas MUST mark th eir NORM-Contaminated Equipment with the lett ers “ 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.)

7. 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

8. EQUIPMENT VS. WASTE Vessels/Pipe are Contaminated at 50 µ R/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 Ra 226 & Ra 228 or 150 pCi/g of their daughter products – The activity level of the waste determines how the waste must be disposed

9. TRANSPORTATION OF NORM Determine if the load is considered “ Radioactive ” p er 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 µ R/hr t hen placard “ Radioactive ” and manifest with prop er shipping name

10. 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

11. Geri Cooley, MS, REM, CSP Regulatory Affairs & HES Manager/ Corporate RSO 888-414-3320 ofc 432-524-4993 fax gcooley@lotusllc.com www.lotusllc.com QUESTIONS?