NORM

1
NORM
2
(No Transcript)
3
Real name George Wendt

• He was born in Chicago, Illinois and attended
  Campion Jesuit High School in Prairie du Chien,
  Wisconsin (the same school attended by Vicente
  Fox). He was kicked out of University of Notre
  Dame after a lack of studying resulted in a
  semester with a 0.00 GPA. He was more successful
  at the Jesuit Rockhurst College, where after
  applying himself, he graduated with a B.A. in
  Economics.

4
I am at the annual George Wendt Fan Club
Meeting , Right?
5
Railroad Commission of Texas

• New Rules Governing
• Oil and Gas NORM
• Guy M. Grossman
• District 3 Director
• Oil and Gas Division

6
Chapter 4 Subchapter F (16 TAC 4.601- 4.632)
Replaces Statewide Rule 94 (previous rule)

• Previous Commission authority (Statewide Rule 94)
  addressed disposal of oil and gas NORM to protect
  public health, safety, and the environment

7
What is Oil and Gas NORM Waste

• Anything that constitutes, is contained in, or
  has contaminated oil and gas waste and exceeds
  the TDSHS exemption criteria of 50 µR/hr
  emanation rate or
• has a concentration of greater than 30 pCi/gm

8
Oil and Gas NORM Chapter 4 Subchapter F (16
TAC 4.601- 4.632)

• Why Amend Rule?
• SB 1338 authorized the Commission to require
  operator/owner to determine if oil and gas
  equipment is contaminated with NORM and to
  identify contaminated equipment
• Bring RRC regulations back in conformance with
  TDSHS radiation regulations
• Simplify rule structure

9
BackgroundRRC NORM Survey

• In 1998 Legislature required RRC to perform NORM
  survey
• In 2000, the RRC surveyed 600 leases
• 59 leases had equipment gt 50 µR/hr
• Of 6000 measurements 3.4 were above 50 µR/hr
• Maximum reading gt1000 µR/hr
• Water tanks, gun barrels, and flow lines had
  highest readings

10
RRC NORM Survey Results

• Dist 7C
• Many Fields
• Dist 8
• High Intensity

11
NORM SurveyOlder Fields Higher NORM

• Average NORM (all gt 50 uR/hr) reading of field
  increases
• with age of field

12
NORM Pathway into OG Waste

• NORM primarily accumulates in og waste when
  radium is dissolved and carried to surface by
  produced water
• Radium is concentrated in scale and sludge when
  precipitated with Ba-, Sr-, or Ca-SO4
• NORM also accumulates in gas processing
  facilities when radon decays to lead-210.
• Radon decay elements accumulate on inner surface
  of gas processing piping (propane-ethane
  processing)

13
Thanks to Nuclear Radiation Industry for Confusion

• Units
• µRoentgen/hr (radiation exposure)
• µRem/hr (also units of Sv or sieverts) (human
  dosage)
• pCi/g (concentration per mass)
• pCi/m2/s (concentration per area over time)
• Rads (also units of grays)
• µ micro millionth
• p pico billionth

14
Chapter 4 Subchapter FPurpose 4.601

• Establish requirements for identification of NORM
  contaminated equipment and disposal of oil and
  gas NORM to protect public health, safety and
  environment
• Provisions do not supercede rules of the Texas
  Department of Health (new TDSHS)

15
Chapter 4 Subchapter FExclusions and Exemptions
4.602

• Exclusionsrecycling oil and gas NORM
  decontamination possession, use, transfer,
  transport, and storage and worker protection
  standards all are under TDSHS
• Exemptionsdisposal of produced water by well or
  discharge to water disposal of decontaminated
  equipment

16
Chapter 4 Subchapter B Identification of
Equipment 4.605

• NORM-contaminated equipment must be identified
  with NORM tag
• If RRC has previously identified NORM
  contaminated equipment, then effective date is
  September 3, 2003
• Otherwise effective date is March 3, 2005

17
Chapter 4 Subchapter B Identification of
Equipment 4.605

• Radiation survey instruments shall comply with
  TDSHS regulations in 25 TAC 289.259(e)
• Detector sensitivity shall be from 1 µR/hr to 500
  µR/hr
• Instruments shall be calibrated, appropriate, and
  operable

18
Chapter 4 Subchapter B Identification of
Equipment 4.605

• Operator must identify NORM-contaminated oil and
  gas equipment with a securely attached, clearly
  visible tag or by marking with paint or ink
• If appropriate tag may include acronym for NORM
  in additional languages

19
Chapter 4 Subchapter B Identification of
Equipment 4.605

• Interconnected equipment (ie wellhead) that is
  NORM contaminated may be identified with a single
  tag while in service.
• Out-of-service, contaminated equipment, removed
  from its prior interconnected status, shall be
  identified individually or as bundled or
  containerized group

20
Chapter 4 Subchapter FWorker Protection
Standards 4.608

• Persons who dispose of oil and gas NORM shall
  comply with provisions of TDSHS regulation
  25TAC289.202 including
• Radiation protection program
• Occupations dose control
• Surveys and monitoring
• Signs and labels
• Record keeping

21
Chapter 4 Subchapter F Worker Protection
Standards 4.608

• TDSHS worker protection standards are not adopted
  by reference because staff is not trained to
  enforce TDSHS regulations
• However, operators shall comply with appropriate
  TDSHS regulations when disposing of NORM

22
Chapter 4 Subchapter FProhibited Disposal 4.611

• Disposal by discharge to surface or subsurface
  water is prohibited
• Disposal by spreading on public roads is
  prohibited
• Burial or landfarming on lease where generated is
  authorized by rule
• All other disposal requires a permit

23
Chapter 4 Subchapter FAuthorized Disposal 4.614

• Placement in PA wellbore
• Burial or Landfarming on lease where NORM waste
  is generated
• By disposal at licensed facility or by injection
  at facility licensed by the TDSHS, if authorized
  to receive such waste

24
Chapter 4 Subchapter FAuthorized Disposal
4.614MethodPlacement in a PA wellbore

• Authorized disposal in PA wellbore
• At least 250 ft below usable quality water
• If placed in tubing, must be retrievable
• Nature of tubing must be known (size, grade,
  weight, depth)
• Cement plug must be set above CIBP or tagged
• Cement must be died with red iron oxide
• Well marked with radiation symbol
• Surf. owner consent required if waste is from off
  lease
• Form W-3A--nature, volume, level, and source

25
Chapter 4 Subchapter FAuthorized Disposal 4.614

• Authorized disposal by burial
• On site where generated
• After mixing, concentration of NORM waste must be
  less than 30 pCi/g of Ra-226 and Ra-228 or 150
  pCi/g of other radionuclides before burial
• Contaminated equipment may not be buried

26
Chapter 4 Subchapter FAuthorized Disposal 4.614

• Authorized disposal by landfarming
• On site where generated
• Concentration of NORM waste must be less than 30
  pCi/g of Ra-226 and Ra-228 or 150 pCi/g of other
  radionuclides after mixing

27
Chapter 4 Subchapter FAuthorized Disposal 4.614

• Authorized disposal by injection of OG NORM
  waste treated at a TDSHS licensed facility in a
  RRC Rule 9 permitted well
• Operator notifies Commission in writing that
  waste meets exemption criteria
• Operator includes copy of TDSHS license
• Operator obtains documentation that waste meets
  exemption criteria

28
Chapter 4 Subchapter FPermit Required for
Injection 4.617

• Standards for issuance of permit
• Required to reasonably protect public health,
  safety, and environment
• Must meet standards for Rule 9 injection well
• Must supply following NORM information
• Physical nature, volume, and level of NORM
• Notice requirements must include NORM information

29
Chapter 4 Subchapter FPermit for Surface
Disposal 4.620

• Standards for issuance of permit
• Required to reasonably protect public health,
  safety, and environment and meet application
  requirements of 3.8
• Concentration of NORM waste must be less than
  than 30 pCi/g of Ra-226 Ra-228 or 150 pCi/g of
  other radionuclides after mixing Concentration of
  NORM waste must be less than 30 pCi/g of Ra-226
  Ra-228 or 150 pCi/g of other radionuclides before
  burial
• Must supply following NORM information
• Physical nature, volume, level of NORM, and
  background
• Dust control methods
• Written authorization from surface owner
• Notice requirements must include NORM information

30
Chapter 4 Subchapter FAlternatives 4.623

• The Commission may approve alternatives to
  conditions in permitting NORM disposal by
  injection or surface disposal if alternative
  methods are protective of public health, safety,
  and environment
• Applicant must submit alternatives in writing
• Review will be completed in 30 days

31
Chapter 4 Subchapter FRecordkeeping 4.626

• The operator shall maintain records on the
  exposure level of equipment, date, location, and
  identification of equipment
• The operator of a unit that generates NORM waste
  shall maintain records on
• Identity of generating property and producing
  formation
• Identity of facility/lease receiving waste
• Nature, volume, and level of NORM waste (in
  pCi/gm)

32
Chapter 4 Subchapter FRecordkeeping 4.626

• The operator of a unit that generates NORM waste
  shall maintain records on
• Operator of lease where waste was generated
• Generating property producing formation
• Facility/lease receiving waste
• Nature, volume, level of NORM (in pCi/gm)
• on the exposure level of equipment, date,
  location, and identification of equipment

33
Chapter 4 Subchapter FRecordkeeping 4.626

• Records shall be retained for 5 years
• Retention period shall be extended during any
  pending Commission enforcement proceeding
• The operator who maintains the records shall make
  them available for examination and copying during
  reasonable working hours and shall file such
  records on request.
• Recordkeeping requirements effective 3/3/2003

34
Chapter 4 Subchapter FInspection 4.629

• The Commission shall have access to properties as
  provided by the Texas Natural Resources Code

35
Chapter 4 Subchapter FPenalties 4.632

• A person who violates requirements of this
  subchapter may be subject of penalties and
  remedies as specified in the Texas Natural
  Resources Code (85.0531) and be subject of
  revocation of the certificate of compliance
• Penalties are up to 10,000/day/violation

36
Texas Department of Health

• If an oil and gas operator possesses, uses,
  transfers, transports, or stores oil and gas
  equipment that contains NORM with an emanation
  rate of 50 µR/hr at any accessible point, then
  the operator is a general licensee of the TDSHS
  and subject or requirements of 25 TAC 289.259

37
Texas Department of Health

• TDSHS is the Texas state radiation control agency
• TDSHS regulates possession, use, transfer,
  transport, and storage of NORM recycling of
  NORM and decontamination of equipment
• TDSHS sets and enforces standards for worker
  protection

38
NORM Information Resources

• American Petroleum Institute
• http//api-ep.api.org/filelibrary/ACF1BE.pdf
• Interstate Oil Gas Compact Commission
• http//www.iogcc.state.ok.us/NORM
• U.S. Dept of Energy
• http//www.ead.anl.gov/pub/dsp_detail.cfm?pubId37
  
• U.S. Geological Survey
• http//pubs.usgs.gov/fs/fs-0142-99/
• U.S. Environmental Protection Agency
• http//www.epa.gov/radiation/tenorm/about.htm
• Railroad Commission of Texas
• http//www.rrc.state.tx.us

39
Scene from Cheers

• Woody Ready for a Beer?
• Norm Isnt it too early for .
• Woody A Beer?
• Norm No , for stupid questions !

40
Frequently asked QUESTIONS
41
1.

• When does an oil and gas operator become a
  general licensee?
• Anyone who mines, extracts, receives, possesses,
  owns, uses, processes, transports, stores,
  transfers for disposal, or recycles NORM is
  automatically a general licensee. 

42
2.

• When does an oil and gas operator or its
  contractor need a specific license from the Texas
  Department of Health?
• Persons who are intentionally decontaminating
  facilities, land, or equipment owned, possessed,
  or controlled by others who treat or process NORM
  waste generated by others are required to have a
  specific license for the activity.  Persons who
  move their decontamination operations from site
  to site are not required to be licensed for each
  individual site. 

43
3.

• Is a license from the Texas department of Health
  required to perform a NORM survey?
• A specific license is not required to do a NORM
  survey. 

44
4.

• Do regulations require NORM surveys of oil and
  gas facilities or equipment?
• No, neither TDHs 289.259 nor RRCs Subchapter F
  specifically require NORM surveys however,
  operator are required to identify
  NORM-contaminated equipment with tags or
  markings.. A NORM survey is necessary to make
  that determination.

45
5.

• Is a specific license needed to pump out tank
  bottoms from production vessels?
• No, because removing tank bottoms from vessels is
  considered routine maintenance. 

46
6.

• How long can NORM waste be stored?
• No time limits on storage are included in
  289.259.

47
7.

• Does land at a producing lease or facility that
  is found contaminated with NORM have to be
  decontaminated within a certain time?
• Neither TDH nor RRC regulations require that the
  land be decontaminated with a certain time
  therefore, the operator may wait to decontaminate
  the land.   Eventually, the land must be
  decontaminated before lease activities cease
  (plugged and abandoned).  However, there may be
  other considerations that warrant a prompt
  decontamination of the site. 

48
8.

• If soil is contaminated by NORM and by oil from a
  spill do the requirements of Rule 91 supersede
  those of Rule 91?
• No, the requirements of both rules must be met
  however, land farming or land spreading may be a
  viable method to meet those requirements.

49
9.

• Is landowner approval needed before doing on-site
  disposal?
• Subchapter F does not require that an operator
  seek the approval of the landowner before
  disposing of NORM waste that was generated on the
  same lease.  However, the operator should be sure
  that the lease agreement does not preclude
  on-lease disposal of NORM.

50
10.

• What are the options to get rid of
  NORM-contaminated equipment?
•      If it is still usable, it can be used again
  for the same purpose (i.e. oil and gas
  production)      It can be decontaminated, then
  sold, recycled, dispose of, etc, like a waste not
  contaminated by NORM     It can be recycled by
  delivering it to a scrap dealer provided that
  dealer will accept the material     It can be
  placed in a well that is being plugged and
  abandoned     It can be disposed of by
  commercial oil and gas NORM disposal company that
  is permitted to dispose of such waste. 

51

• It can be disposed of by commercial oil and gas
  NORM disposal company that is permitted to
  dispose of such waste. 

52
11.

• . Is a minor permit under Rule 8, needed to haul
  NORM-contaminated pipe?
• No, because the transport of NORM is under TDH
  jurisdiction. 

53
12

• Is a minor permit under Rule 8 required to move
  NORM waste from one lease to another lease for
  disposal?
• A minor permit is required only if a minor permit
  is necessary for that type of waste regardless if
  it contains NORM.  For example, a minor permit is
  necessary to move tank bottoms, but not move
  tubing.

54
13.

• The recent rule change required legible signs be
  posted around NORM waste sites, but did not
  stipulate the sign parameters. What are the sign
  requirements?
• As a matter of administrative policy, the signs
  should use one inch tall letters consistent with
  the sign requirements of Statewide Rule 3 which
  reads "The signs and identification required by
  this section shall be in the English language,
  clearly legible, and ... shall be in letters and
  numbers at least one inch in height."

55
Other Questions on NORM or other Subjects ? There
really are no bad Questions other than the ones
not asked !