Waste Management Procedures
NORM Equipment and Pipe
Before you begin
Description
/ Naturally Occurring Radioactive Material (NORM) is material containing radioactive isotopes, generally Radium-226 and Radium-228, that have leached from geologic formations and have been transported to the surface dissolved in the produced water. Barium sulfate scale forms in tubing and process equipment through which the produced water has passed. Radium sulfate scale forms as a trace impurity in the barium sulfate scale.There is a subtle difference in the definition of units:
· Louisiana Rules: --30 picocuries per gram of
either Radium 226 or Radium 228
· Texas Rules: --30 picocuries per gram of
Radium 226 combined with Radium 228
NOTE: Picocuries can only be determined by laboratory analysis.
Equipment is exempt from NORM regulation if the radiation level does not exceed 50m Roentgens/hr at any accessible point.
Scale is regulated as follows:
Louisiana Rules
· If 5 (or more) picocuries per gram of either Radium 226 or Radium 228,
it is regulated by Louisiana Department of Environmental Quality as NORM.
NORM waste may be shipped with no DEQ NORM Manifest as long as it is below 30 picocuries per gram of either Radium 226 or Radium 228. The following is required in this situation:
q Oilfield waste shipping control ticket (UIC-28)
q NORM Waste must be disposed of in an approved facility
· If 30 (or more) picocuries per gram of either Radium 226 or Radium 228:
q Louisiana DEQ NORM Waste Manifest, RPD-37, must accompany shipment.
Texas Rules
· Texas regulates the waste as NORM at 30 (or more) picocuries per gram of Radium 226 combined with Radium 228, but there are no forms.
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NORM Equipment and Pipe
Before You Begin, (continued)
Description
(continued)
/ US DOT Rules· If 2000 (or more) picocuries per gram of total radioactivity:
· In addition to the above, DOT Hazardous Material rules apply:
q Shipping papers, container requirements, emergency response.
q Place proper DOT label according to the following (Non Exclusive Use Shipment):
(1) Radioactive White I label -- If less than 500 Microrem per hour at the surface.
(2) Radioactive Yellow II label – If equal to or more than 500, but less than 50,000 Microrem per hour at the surface.
(3) Radioactive Yellow III label -- If equal to or more than 50,000 Microrem per hour at the surface.
Category
/ Scrap Metal is· Non-hazardous
· Non-exempt recyclable material
NORM is
· E&P exempt waste
· Radioactive waste
Analysis
/ For metal surfaces exposed to the flow of produced water:· Use a gamma-ray scintillator capable of detecting 50m R/hr (50m Roentgens/hr) [Ludlum Model 3, or Model 19, Survey Meter].
· Establish background level using the gamma-ray scintillator.
· If test is higher than twice background level, send for lab testing.
For metal surfaces not exposed to the flow of produced water:
· No analysis is required
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NORM Equipment and Pipe
Before You Begin, (continued)
Accumulation
/ · Contact the E H & S Department for assistance if NORM storage is required.· Place in storage baskets and bins, and/or skids.
· If NORM contaminated, plug openings with newspaper, wrap in visquene, and duct tape to seal ends and prevent leakage.
· If material is questionable, check it with a gamma-ray scintillator.
· Do not mix NORM with any other materials.
· NORM and NORM-free scrap metals must be separated before shipment.
· On federal offshore facilities:
(1) Permission to store NORM must be approved by BSEE Regional Supervisor for Field Operations.
(2) NORM storage containers must be secured to the platform to avoid loss during storms or hurricanes.
(3) Storage time cannot exceed one year.
Waste Reduction
/ · After cleaned equipment or piping of NORM, recycle scrap metal.· In Louisiana, equipment with NORM contamination can be reused without being cleaned if not out-of-service for over 12 months.
Disposal
/ Scrap metals free of NORM:1) Send to a facility that will reuse or recycle the metal.
Scrap metals coated with NORM scale:
1) To separate the NORM scale from the scrap metal, send to a facility that is specifically licensed for NORM services by the Louisiana Radiation Division.
2) For the scrap metal separated by the licensed NORM services facility:
· Send to a facility that will reuse or recycle the metal.
3) For the NORM scale separated by the licensed NORM services facility:
· Send to a commercial facility that will dispose of NORM in a CLASS II [E&P Waste] disposal well.
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NORM Equipment and Pipe
Before You Begin, (continued)
Recordkeeping
/ · If going to a Louisiana E&P Waste facility, no DEQ NORM manifest is needed below 30 picocuries per gram of Radium 226 or Radium 228.· At 30 (or more) picocuries per gram of Radium 226 or Radium 228, complete Louisiana DEQ NORM Manifest, RPD-37, prior to transportation.
· List on general cargo section [Section II] of the Fieldwood Energy Shipping Manifest.
· Complete parts I and II of E&P Waste Shipping Control ticket UIC-28, at offshore facility and Part III at Commercial facility for exempt waste.
· Maintain a copy of records at offshore and shorebase facilities while active.
· Send original manifests with shipment.
· Retain records for three years.
· Retain records of the RPD-37 (permanently). Louisiana Radiation Regulation 33 LAC 1418. E. 1.c. states, “retain one copy.” It does not state for how long you should retain the completed Louisiana DEQ NORM Manifest, RPD-37.
Shipping Instructions: NORM Equipment and Pipe
(less than 2000 picocuries per gram)
(NORM Free or less than 5 picocuries per gram)
1. Evaluate for possibility of NORM contamination.
DOT rules for radioactive material do not apply to NORM scale that has less than 2,000 picocuries [0.002 microcurie] per gram of total radioactivity.
Louisiana DEQ rules apply at 5 picocuries per gram of either Radium 226 or Radium 228. If at or above 5 picocuries per gram of NORM Radioactivity—GO TO THE NEXT PAGE
If at or above 2000 picocuries per gram of NORM Radioactivity—GO TO PAGE 7
If below 5 picocuries per gram (In Texas, if below 30 picocuries of Radium 226 and Radium 228 combined) of NORM Radioactivity--CONTINUE
2. Call or FAX Dock/Base to coordinate materials arrival at Dock/Base.
3. Package Scrap Metals as follows:
Place in scrap metal basket.
NOTE:
NORM AND NORM-FREE SCRAP METALS MUST BE SEPARATED PRIOR TO SHIPMENT.
If less than 2,000 picocuries [0.002 microcurie] per gram of total radioactivity:
4. Mark Package:
a. No DOT marking is required.
b. Stencil Container-“Fieldwood Energy” and the generator’s location (i.e. Eugene Island 158)
5. Label Package:
No DOT label is required.
6. Prepare shipping papers:
a. Complete entry in General Cargo Section [Section II] of the Fieldwood Energy Shipping Manifest (See Example)
b. Send to customary dock facility as scrap metal.
7. Placard Vehicle/Vessel:
No DOT placard is required
8. Load cargo in accordance with the following shipping limitations:
No DOT hazardous material restrictions apply
9. Include MSDS with shipment if NORM contaminated
Shipping Instructions: NORM Equipment and Pipe
(less than 2000 picocuries per gram)
(from 5 to 2000 picocuries per gram)
1. Evaluate for possibility of NORM contamination if material was once part of production process.
2. Call or FAX Dock/Base to coordinate materials arrival at Dock/Base.
3. Package Scrap Metals as follows:
a. Place in scrap metal basket.
b. If NORM contaminated, plug openings with newspaper, wrap in visquene, and duct tape to seal ends and prevent leakage.
NOTE:
NORM AND NORM-FREE SCRAP METALS MUST BE SEPARATED PRIOR TO SHIPMENT.
If less than 2,000 picocuries per gram of total radioactivity:
4. Mark Package:
a. No DOT marking is required.
b. Stencil Container-"Fieldwood Energy” and the generator's location (i.e. Eugene Island 158)
5. Label Package:
No DOT label is required
6. Prepare shipping papers:
a. If, you are transporting scrap for removal of scale Complete Non-Hazardous Oilfield Waste (NOW) Shipping Control Ticket, form UIC-28. (See Example)
DO NOT SIGN TICKET. It is required to be signed in the presence of the truck driver. Dock personnel must sign.
b. At 30 [and more] picocuries per gram of Radium 226 or Radium 228 in the scale, complete Louisiana NORM Manifest.
c. Equipment, which contains NORM, does not require the Louisiana NORM Manifest if the maximum radiation does not exceed 50m Roentgens/hr at any accessible point.
d. Complete entry in General Cargo Section [Section II] of the Fieldwood Energy Shipping Manifest (See Example)
e. Send to customary dock facility as scrap metal. (See Example)
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Shipping Instructions: NORM Equipment and Pipe
(continued)
7. Placard Vehicle/Vessel: No DOT placard is required
8. Load cargo: No DOT hazardous material restrictions apply
9. MSDS: No MSDS is required
Shipping Instructions: NORM Equipment and Pipe
(NORM total radioactivity 2000 (or more) picocuries per gram)
1. Evaluate for possibility of NORM contamination.
DOT rules for radioactive material do not apply to produced sand that has less than 2,000 picocuries [0.002 microcurie] per gram of total radioactivity.
Louisiana DEQ rules apply at 5 picocuries per gram of Radium 226 or Radium 228.
Texas rules apply at 30 picocuries per gram of Radium 226 & Radium 228 combined.
2. Call or FAX Dock/Base to coordinate materials arrival at Dock/Base.
3. Package Scrap Metals as follows:
a. Place in scrap metal basket.
NOTE:
NORM AND NORM-FREE SCRAP METALS MUST BE SEPARATED PRIOR TO SHIPMENT.
4. Package Sand/Sludge as follows:
If material has 2,000 picocuries [0.002 microcurie] or more per gram of total radioactivity, DOT rules for radioactive material do apply:
a. Place Sand/Sludge in a DOT Specification 7A Type A package. This is very similar to a removable head drum.
b. Allow to stand for several minutes.
c. Pump off water to production system, leaving solids and sludges in drum.
5. Mark Package:
a. If contaminated with NORM [equal to or greater than 2,000 picocuries per gram of total radioactivity], mark container "Radioactive Material, LSA, n.o.s. (oilfield NORM) RQ, 7, UN2912."
b. The reportable quantity (RQ) for Radium 226 in equilibrium with its daughters is 0.053 curie [53 millicuries = 53,000 microocuries = 53,000,000,000 picocuries]. If no single container holds 0.053 curie [53 billion picocuries] or more, the letters RQ are not required.
c. Stencil Container-"Fieldwood Energy" and the generator's location (i.e. Eugene Island 158)
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Shipping Instructions: NORM Equipment and Pipe
(continued)
6. Label Package:
a. If contaminated with NORM [equal to or greater than 2,000 picocuries per gram of total radioactivity], place proper DOT label according to following (Non Exclusive Use Shipment):
(1) Radioactive White I label -- If less than 500 Microrem per hour at the surface.
(2) Radioactive Yellow II label – If equal to or more than 500 but less than 50,000 Microrem per hour at the surface
(3) Radioactive Yellow III label --If equal to or more than 50,000 Microrem per hour at the surface..
b. Only radioactive material requires duplicate labels on at least 2 sides or 2 ends (other than the bottom) for drums and other non-bulk containers.
c. For packages having a volume over 64 cubic feet (475 gallons) and for portable tanks of less than 1000 gallons: place labels on at least two ends (other than the bottom) or two sides.
7. Prepare shipping papers:
a. If, you are transporting scrap for removal of scale Complete Non-Hazardous Oilfield Waste (NOW) Shipping Control Ticket, form UIC - 28. (See Example)
DO NOT SIGN TICKET. It is required to be signed in the presence of the truck driver. Dock personnel must sign.
b. At 30 [and more] picocuries per gram of Radium 226 or Radium 228 in the scale, complete Louisiana NORM Manifest.
c. Equipment, which contains NORM, does not require the Louisiana NORM Manifest if the maximum radiation does not exceed 50m Roentgens/hr at any accessible point.
d. If equal to or greater than 2,000 picocurie per gram complete entry in Hazardous Materials Section [Section I] of the Fieldwood Energy Shipping manifest (See Example).
· Enter the description, “Radioactive material LSA, n.o.s. (oilfield NORM in pipe and equipment) RQ, 7, UN2912”, in a blank line in Section I.
· Enter the number “162” in the column headed “Emergency Guide Number”. The reportable quantity (RQ) for Radium 226 in equilibrium with its daughters is 0.053 curie [53 billion picocuries].
· If no single container holds 0.053 curie [53 billion picocuries] or more, the letters RQ are not required.
e. Certain routing is required for “highway route controlled quantities” of radioactive material (an amount equal to 3,000 times the A2 value as specified in 49 CFR 173.435 the A2 value for Radium 226 is 0.05 curies. A highway route controlled quantity of Radium 226 is 3,000 times 0.05 curies or 150 curies.) The disposal facility can assist with this determination.
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Shipping Instructions: NORM Equipment and Pipe
(continued)
8. Placard Vehicle/Vessel:
There are only three situations when the “Radioactive” placard is required:
a. If the Radioactive III label is required. This is required when the radioactivity of the container is equal to or more than 50,000 Microrem per hour at the surface.
b. Exclusive use shipments of low specific activity material and surface contaminated objects transported in accordance with 49 CFR 173.427 (b)(3)
c. Exclusive use shipments of low specific activity material and surface contaminated objects transported in accordance with 49 CFR 173.427 (c)
9. Load cargo in accordance with the following shipping limitations:
WATER / RESTRICTIONSCargo and Passenger Vessels / On deck or under deck
Other Requirements / None
10. No MSDS is required
UIC - 28
/ OFFICE OF CONSERVATION / Manifest No.P.O. BOX 94275
1726545 / BATON ROUGE, LA 70804-9275 / CONSERVATION COPY
ORIGINAL
1 END5
PART I
/TO BE COMPLETED BY GENERATOR
CODES0152 / ↔ /
Generator
/ Fieldwood Energy LLCAddress / 2014 W. Pinhook Road, Suite 800 / (337) 735-8210
City/State/Zip / Lafayette, LA, 70510 / Telephone No.
ORIGINATION OF WASTE (see instructions on back)
999997 / ↔ /
Well Name & No. / Description
/ OCS-G-12205 / ↔ / LUW Type /
Field
/ Eugene Island 175WASTE IDENTIFICATION AND AMOUNT (IN 42 GALLON BARRELS)
01 Salt Water / 07 Prod. Sands/Solids / 3 / 13 BS &W Waste
02 Oil Base Mud / 08 Fresh Water / 14 Pipeline Test Water
03 Water Base Mud / 09 Rainwater / 15 Com. Facility Waste
04 Completion Fluids / 10 Washout Water / 16 Oil Spill Waste
05 Prod. Pit Sludges / 11 Washout Pit Water / 50 Salvage Crude Oil
06 Prod Tank Sludges / 12 Gas Plant Waste / 99 Other
LA PSC permit / DESTINATION OF WASTE / Phillips Servcies
Commercial Facility (Company) Name
LA-6229 –S01 / 756 Geradline Road Gibson, La. 70356
↔ /
Site Name
NOTE: MUST BE SIGNED IN THE PRESENCE OF THE TRANSPORTER!CERTIFICATION: / The waste described above was consigned to the carrier named below. I certify that the foregoing is true and correct to the best of my knowledge / am
Sam Bourque / 1/1/11 / pm
Signature of Generator’s Authorized Agent / Date and Time of Shipment
PART II:
/TO BE COMPLETED BY TRANSPORTER IN PRESENCE OF GENERATOR
PSC PERMIT9997 / ↔ / Transporter / Graham Gulf, Inc. / (985) 385-3475
Address
/ P.O. Box 2291 / Telephone No.City/State/Zip / Morgan City, LA, 70380 / Truck License No.
Trailer License No.
If transported by barge, barge and tug identification
Barge and Tug Id.
CERTIFICATION: / I certify that the waste in quantity above was received by me for shipment to the above destination. / am
pm
Signature of Transporter’s Authorized Agent / Date and Time Received
PART III
/TO BE COMPLETED BY COMMERICAL FACILITY
LA PSC permitFacility (Company) Name / Phillips Services
LA-6229 S-01 / ↔ /
Site Name
/ 756 Geraldine Road Gibson, La. 70356CHEMICAL ANALYSIS
Chloride (mg/l) / Conductivity (mmhos/cm) / pH
CERTIFICATION: / I certify that the waste described in Part I was received by me via the transporter described in Part II