SP 1170 NORM by Zw48Ik7

VIEWS: 19 PAGES: 21

									HEALTH, SAFETY AND ENVIRONMENT SPECIFICATIONS
Naturally Occurring Radioactive Materials (N.O.R.M.)


DOCUMENT ID   - SP 1170
REVISION      - 2.0
DATE          - 15/07/2002
                                                                                      HSE – SPECIFICATION
                                                                                         Setting Clear Requirements




Authorised for Issue by the HSE IC 15/07/2002




Document Authorisation
Document Authority                        Document Custodian                 Document Author
‘dapo Oguntoyinbo                         Wayne Austin                       Wayne Austin
Ref. Ind: CSM                             Ref. Ind: CSM/32                   Ref. Ind: CSM/32
Date: 15/07/02                            Date: 15/07/02                     Date: 15/07/02

The following is a brief summary of the four most recent revisions to this document. Details of all revisions prior
to these are held on file by the Document Custodian.

Version No.       Date          Author                    Scope / Remarks
Version 2.0       15/05/02      Wayne Austin              Editorial changes. New format. Deletion of NORM Map
                                CSM/32                    (App. A), revision of existing procedures and inclusion
                                                          of new procedures. Modifications to forms.
Version 1.0       20/03/00      Muralee                   Original Specification
                                Thummarukudy




User Notes:

The requirements of this document are mandatory. Non-compliance shall only be authorised by CSM through
STEP-OUT approval.

A controlled copy of the current version of this document is on PDO's EDMS. Before making reference to this
document, it is the user's responsibility to ensure that any hard copy, or electronic copy, is current. For
assistance, contact the Document Custodian.

This document is the property of Petroleum Development Oman, LLC. Neither the whole nor any part of this
document may be disclosed to others or reproduced, stored in a retrieval system, or transmitted in any form by
any means (electronic, mechanical, reprographic recording or otherwise) without prior written consent of the
owner.




Users are encouraged to participate in the ongoing improvement of this document by providing constructive
feedback.




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          Contents

          1.                      Introduction............................................................................................. 1
               1.1      PURPOSE............................................................................................................... 1
               1.2      SCOPE .................................................................................................................. 1
               1.3      DEFINITIONS.......................................................................................................... 1
               1.4      DELIVERABLES ........................................................................................................ 2
                  1.4.1       Records ........................................................................................................ 2
                  1.4.2       Reports ........................................................................................................ 2
                  1.4.3       Competency ................................................................................................. 3
               1.5      RESPONSIBILITIES ................................................................................................... 3
                  1.5.1       Radiation Advisory Committee ....................................................................... 3
                  1.5.2       Corporate Radiation Focal Point ..................................................................... 3
                  1.5.3       Asset Managers ............................................................................................ 4
                  1.5.4       Corporate Functional Discipline Heads ............................................................ 4
                  1.5.5       Area Coordinators/Project Managers/Well Site Supervisors .............................. 4
                  1.5.6       Competent Persons ....................................................................................... 5
                  1.5.7       Contract Holders ........................................................................................... 5
                  1.5.8       Contractors ................................................................................................... 5
                  1.5.9       Interior Radiation Focal Point ......................................................................... 5
                  1.5.10      Radiation Protection Advisor .......................................................................... 5
                  1.5.11      Corporate Occupational Hygienists ................................................................. 6
                  1.5.12      Corporate Environmental Advisors .................................................................. 6
               1.6      PERFORMANCE MONITORING ...................................................................................... 6
               1.7      REVIEW AND IMPROVEMENT ....................................................................................... 6
               1.8      REPORTING............................................................................................................ 6
          2.                      Performance Requirements ..................................................................... 7
               2.1    REGULATIONS AND PERFORMANCE STANDARDS ............................................................... 7
               2.2    MANAGEMENT OF NORM MATERIAL ............................................................................. 7
                 2.2.1    Monitoring .................................................................................................... 7
                  2.2.2       Handling of Radioactive material .................................................................... 7
                  2.2.3       Transport of Radioactive Material ................................................................... 8
                  2.2.4       Storage of Radioactive Material ...................................................................... 9
                  2.2.5       Disposal of Radioactive Material ..................................................................... 9
                  2.2.6       NORM Restricted Areas ................................................................................. 9
          Appendix A:             NORM Generation Form .........................................................................10

          Appendix B:             NORM – Record of Movement................................................................11

          Appendix C:             Personal Protective Equipment for NORM Handling .............................12

          Appendix D: Work Instructions for Handling NORM Contaminated Materials
          during Pigging Operations ...........................................................................................13

          Appendix E: Work Instructions for Handling NORM Suspect Materials during Well
          Engineering and Services Operations...........................................................................15

          Appendix F:             Work Instructions for Vessel Entry of NORM Contaminated Vessels ....17




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          1.    Introduction

          1.1   Purpose
                This specification describes PDO's minimum requirements for managing Naturally
                Occurring Radioactive Materials (NORM), which have the potential to be a hazard to
                human health or to harm the environment, as a result of PDO’s activities, products
                or services.

                NORM will be handled in PDO on the basis of the precautionary principle and
                demonstrable due diligence. This involves:

                   Ensuring that no PDO employee or contractor is exposed to levels of ionising
                    radiationsin excess of accepted international standards.
                   Minimising the exposure of PDO employees and contractors to any levels of
                    ionising radiations.
                   Assuming NORM is present (where the potential exists) until proven otherwise.
                   Continuously monitoring the NORM levels in PDO operations and areas.
                   Constantly updating our knowledge of NORM based on international best
                    practices and scientific understanding.

          1.2   Scope
                PDO has identified NORM as an issue to be managed in its operations. PDO have
                already acquired experience in NORM monitoring, handling, transport and storage.
                PDO is yet to undertake any substantial work on NORM treatment and disposal.

                This specification covers PDO’s practices for:
                 Monitoring, handling, transport and storage of NORM contaminated materials
                   and
                 Working in NORM suspect, supervised and restricted areas.

                It does not cover issues of treatment and disposal of NORM, except as specified in
                section 2.1.5.

          1.3   Definitions

                Activity Level: The number of radioactive atoms disintegrating per second

                Background: The radiation to which an individual is exposed arising from natural
                radiation sources such as terrestrial and cosmic radiation. For measurement
                purposes, it is defined as the true meter reading of a contamination monitor in
                counts per second (cps) when read in an area known to be free of NORM.

                Becquerel (Bq): The System International (SI) unit for measurement of radioactivity
                (1 Bq = 1 Nuclear disintegration/sec).

                Dose rate: The absorbed rate of radiation measured per unit of time (measured in
                units of micro or milli seiverts per hour - Sv/hr or mSv/hr).




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                  Monitoring: The measurement of exposure, dose rate or contamination for the
                  purpose of assessment and control of exposure of persons and the environment, to
                  radioactive materials.

                  NORM: Naturally Occurring Radioactive Materials are materials produced by
                  members of the decay series of naturally occurring Uranium–238 and Thorium-232
                  or other similar radioactive nuclei.

                  Norm Contaminated Area: Is an area where the NORM count in the area, as
                  measured by a NORM contamination meter, exceeds the background levels by at
                  least 5 counts per second on the Mini Instruments series 900 with a 44A probe.

                  NORM Contaminated Materials: NORM contaminated materials are produced when
                  NORM is attached to the surface of materials either directly as elemental deposits or
                  indirectly incorporated in salt deposits.

                  NORM Counts: The response of a contamination monitor expressed in counts per
                  second (cps). The recommended monitor is currently the Mini Instruments series
                  900 with a 44A-scintillation probe.

                  NORM Restricted Area: An area is classified as a NORM Restricted Area when the
                  dose rate in that area equals or exceeds 2.5Sv/hr. (NORM Restricted Area covers
                  both controlled and supervised areas as defined in MD 249/97).

                  Radioactive Material: Is a material classified as radioactive, if the total activity is
                  greater than 100 Bq/g. 1

                  Seivert (Sv): The System International (SI) unit for measurement of effective dose.

                  TENORM Technologically Enhanced Naturally Occurring Radioactive Materials are
                  NORM which have been selectively concentrated by production processes resulting.
                  For the purpose of this specification NORM will include TENORM.


          1.4     Deliverables

          1.4.1   Records
                  Records shall be maintained to document the implementation of this Specification,
                  including sampling methodology and data interpretation techniques (refer to CP 122
                  HSE Management System Manual, Part 2 Chapter 6).

          1.4.2   Reports
                  NORM monitoring data (including non-detectable or zero results data) shall be
                  entered into the Radiation Database (LIMS maintained by TKM).

                  PDO staff: Any non-compliances with this Specification shall be notified,
                  investigated and reported per the ‘Non Compliance Report Form’ in Chapter 6 of
                  PDO’s CP 122 HSE Management System Manual.

                  1
                    This level is expected to be lowered pending completion of risk-based scenario
                  analyses and subsequent cost implication analyses.




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                      Contractors: Any non-compliances with this Specification shall be notified,
                      investigated and reported per the ‘Non Compliance Report Form’ in Chapter 6 of
                      PDO’s CP 122 HSE Management System Manual.

          1.4.3   Competency
                  Individuals tasked with NORM management responsibilities will be expected to
                  acquire and demonstrate competencies commensurate with their assigned
                  responsibilities.


          1.5         Responsibilities

          1.5.1   Radiation Advisory Committee
                  The Radiation Advisory Committee (RAC) defines and approves PDO’s policy and/or
                  specifications and procedures with respect to operational and administrative
                  management of radiation protection, including NORM. The RAC is advised by the
                  Radiation Protection Adviser (RPA – an external consultant) who will be the source of
                  expertise for all matters concerning protection against the hazards of ionising
                  radiation.

                  The RAC will ensure, through development of appropriate policies, specifications,
                  and/or procedures,

                       The application of radiation protection principles as laid down in publication 60 of
                        the International Commission on Radiological Protection (ICRP).
                       The protection of its personnel, contractors, members of the public and the
                        environment against the hazards of exposure to ionising radiation due to PDO
                        work activities.
                       The avoidance of loss of sources and uncontrolled release of substances
                        contaminated with Naturally Occurring Radionuclides (NORs).
                       The minimisation of radiological effects of PDO work activities carried out in the
                        past.
                       The avoidance of the need for classified PDO radiation workers, wherever
                        reasonably practicable.

                  The RAC reports to PDO’s Managing Directors Committee (MDC). The RAC is
                  comprised of:
                  Chairman                                                           TSD
                  Corporate Radiation Focal Point (acts as the RAC secretary)        CSM/32
                  Environmental Advisor                                              CSM/22
                  Operations Representative                                          OSO
                  Production Chemistry Manager                                       TKM
                  DOIRC (Drilling) Representative


          1.5.2   Corporate Radiation Focal Point
                  The Corporate Radiation Focal Point (CRFP) will be the first source of expertise within
                  PDO for matters concerning the protection against the hazards of ionising radiation.
                  When lacking knowledge or information the CFRP may call in the help/advice of the
                  RPA. Further, the CRFP:




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                         Is secretary to the RAC.
                         Communicates with competent authority on PDO matters concerning the
                          protection against the hazards of ionising radiation.
                         Monitors the PDO radiation protection policy implementation.
                         Is current on all potential ionising radiation issues within PDO.
                         Is the radiation data base owner (record/register keeping for sources, survey
                          data, analysis results, waste production, leak tests, transport documents,
                          contaminated equipment, radiation workers, recorded dose).
                         Is contract holder for the external RPA contract.


          1.5.3   Asset Managers
                  Asset Managers are responsible for ensuring that NORM in their area of responsibility
                  is managed in accordance with the requirements of this Specification. Asset
                  Managers are responsible for ensuring that the presence of NORM is investigated in
                  their area. If NORM Contaminated areas are identified, Managers shall ensure that:

                          the issue is investigated further to identify the source and manage it
                          adequate budgetary support is provided to cover the NORM investigations,
                           handling, and storage, and
                          management of NORM is periodically reviewed and that auditable records are
                           available of such reviews.

                      In the event that circumstances prevent compliance with this Specification, Asset
                      Managers shall seek the advice and if necessary, a ‘step-out approval’ from the
                      Document Authority. This approval requires recording subject areas, which do not
                      conform as a non-compliance (refer to the ‘Non Compliance Report Form’ in CP 122
                      HSE Management System Manual, Part 2, Chapter 6).


          1.5.4   Corporate Functional Discipline Heads
                  Corporate Functional Discipline Heads are responsible for ensuring that the
                  requirements of this Specification, if applicable, are reflected in the documents for
                  which they are responsible.


          1.5.5   Area Coordinators/Project Managers/Well Site Supervisors
                  Area Coordinators, Project Managers and Well Site Supervisors are responsible for
                  ensuring that people who work under them are not inadvertently exposed to NORM
                  and that NORM contaminated materials are managed according to the requirements
                  of these specifications. In particular, they shall:

                          ensure that all areas/operations in their responsibility are investigated for
                           possible presence of NORM as applicable
                          ensure that when NORM is identified all the correct operating procedures are
                           followed for its handling, transport and storage
                          ensure that all staff who may be exposed to NORM as a part of their job are
                           trained to be aware of NORM contaminated/restricted areas and the
                           implications on their work and
                          ensure that the correct personnel protective equipment is available for all staff
                           who may work with NORM contaminated materials or work in NORM
                           contaminated or restricted areas.



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          1.5.6   Competent Persons
                  Competent persons, as determined by the CRFP, are those individuals who have
                  specific responsibilities or tasks pertaining to NORM management and have received
                  the requisite training to carry out those responsibilities or tasks. Competent persons
                  may include HSE Advisors, Production Supervisors, Laboratory Technicians, Well Site
                  Supervisors, Production Operators, and others.


          1.5.7   Contract Holders
                  Contract Holders are responsible for ensuring that the contractors, while working on
                  PDO projects, follow all applicable PDO Operating Procedures with specific reference
                  to NORM.


          1.5.8   Contractors
                  Contractors are responsible for ensuring that discharges to the environment
                  generated in the course of carrying out their contractual requirements, are managed
                  in accordance with the requirements of this Specification and reported, when
                  applicable, to the Contract Holder and that their personnel are appropriately trained
                  to manage NORM in accordance with this specification.


          1.5.9   Interior Radiation Focal Point
                  The Interior Radiation Focal Point (IRFP) is responsible for ensuring that operational
                  areas are provided with prompt operational advice and support for NORM monitoring,
                  handling, and storage. This may include advice on:

                       NORM samples taken, handling and proper transport and storage.
                       Co-ordination of training of PDO competent persons for managing NORM.
                       Co-ordination of training for line departments as requested.
                       For PDO auditors to give assurance that PDO have exercised due diligence in
                        the management of NORM.
                       Maintenance of Radiation Data Base with respect to NORM entries and
                        preparation of reports as required by the RAC.


          1.5.10 Radiation Protection Advisor
                  The Radiation Protection Advisor (RPA) is responsible for providing PDO management
                  with competent advice on the management of NORM in PDO in accordance with the
                  requirements of the Government of the Sultanate of Oman and guidelines of the
                  international agencies working in the area. In particular he shall:

                       Provide guidance on ‘Operating Procedures’ for managing (monitoring,
                        handling, transport, storage, treatment and disposal) of NORM as well as work
                        instructions for working in NORM contaminated or restricted areas.
                       Audit field operations involving NORM.
                       Train PDO competent persons for managing NORM.




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          1.5.11   Corporate Occupational Hygienists
                   Occupational Hygienists are responsible for providing PDO management with
                   competent advice on the assessment and control of occupational health hazards
                   relating to NORM.


          1.5.12   Corporate Environmental Advisors
                   Environmental Advisors are responsible for providing PDO management with
                   competent advice on the storage, treatment and disposal of NORM. At the direction
                   of the RAC, they will take a lead role in negotiating/interfacing with appropriate
                   governmental agencies for matters pertaining to NORM.


          1.6      Performance Monitoring
                   An integrated NORM monitoring program shall be developed, implemented and
                   maintained to demonstrate compliance with this Specification and any additional
                   requirements specified in an Environmental Permit. The monitoring program should
                   supply the necessary data to prepare the required reports for NORM.

                   Any non-compliance with this Specification shall be notified, investigated and
                   reported (refer to CP 122 HSE Management System Manual, Part 2 Chapter 6).

          1.7      Review and Improvement
                   Any user of this document who encounters a mistake or confusing entry is
                   requested to immediately notify CSM using the form provided in CP 122 HSE
                   Management System Manual, Part 2 Chapter 3).

                   This Specification shall be reviewed every 4 years. However changes to the current
                   version may be made in less than four years as the need arises depending upon the
                   issue of new and relevant environmental legislation and/or major organisational
                   changes in PDO.

          1.8      Reporting
                   A report shall be prepared by the IRFP and sent to the CRFP in accordance with the
                   RAC meeting schedule. The report will include:
                    Number of areas surveyed.
                    Locations of NORM contaminated areas.
                    Locations of identified NORM areas.
                    Inventory of NORM contaminated equipment and materials in Zauliyah Storage
                       Site
                    Results of NORM analyses.




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          2.      Performance Requirements

          2.1     Regulations and Performance Standards
                  The Ministry of Regional Municipalities, Environment and Water Resources
                  (MRMEWR) issued MD 249/97: Regulations for the Control and Management of
                  Radioactive Materials. This Specification meets or exceeds the requirements set
                  forth by the MRMEWR and complies with recognised international standards.

                  The performance standard for NORM in PDO is based on the Shell International
                  Exploration and Production HSE-MS Manual (EP 95-0000 series). This requires that
                  PDO undertake operations involving NORM contaminated materials according to the
                  As Low As Reasonably Achievable (ALARA) principle.

                  These Specifications address the management of NORM containing materials and
                  the precautions to be followed while working in NORM suspect and restricted
                  areas. This includes monitoring, handling, transport, storage, treatment and
                  disposal of NORM.

                  All work involving NORM materials shall be recorded in the NORM Generation Form
                  (Appendix A).

          2.2     Management of NORM Material

          2.2.1   Monitoring
                  All operations, where there is a reason to believe NORM contamination exists, must
                  be monitored using a contamination monitor. All operations involving exposure to
                  production fluids have the potential for NORM contamination. In particular, oil
                  sludges, pigging wastes, tubulars and water/well accessories from reservoir
                  locations where NORM has been detected in the past should be considered.

                  Any material recording 5-cps above background levels must be regarded as
                  radioactive until proven otherwise by sample analysis. Samples must be sent for
                  activity analysis through the Production Chemistry Laboratory, to the Sultan Qaboos
                  University.

                  If the material shows an total activity level 100 Bq/g or more, it must be classified
                  as radioactive material and sent for safe storage at PDO’s waste storage facility at
                  Zauliah as soon as possible.

                  Contaminated items, which are shown by activity analyses to have an activity of
                  less than 100 Bq/g Total Activity can be dealt with as normal non-radioactive items.

                  A record of the quantity and activity of all NORM material sent to Zauliyah must be
                  kept using the forms given in Appendix B.

          2.2.2   Handling of Radioactive Material
                  All NORM contaminated material must be handled in a manner that ensures no
                  ingestion or inhalation of contaminated material can take place.




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                  The general principles for all operations are:

                       The number of personnel involved in the operation must be kept to a minimum.
                       Access to NORM areas must be controlled.
                       All personnel involved with the work must wear personal protective equipment,
                        as given in Appendix C
                       The following activities are prohibited in the area: eating, drinking, smoking,
                        licking glued labels, and the use of cosmetics, personal handkerchiefs and
                        mouth pipettes.
                       All personnel must decontaminate and wash with water before they leave the
                        site of operation.
                       All personnel working with NORM must be monitored with a contamination
                        meter before leaving the area (after washing).
                       All NORM contaminated materials or silts must be wrapped, sealed or drummed
                        before they leave the area of operation.

                  Work instructions for handling NORM suspect debris during pigging operations and
                  well services operations are described in Appendix D and E, respectively.


          2.2.3   Transport of Radioactive Material
                  The following procedure are to be followed when transporting NORM:

                       The openings to contaminated valves, spool pieces and pumps will be covered
                        with polyethene, will be labelled as NORM contaminated and be placed inside a
                        standard container.
                       Contaminated tubulars will be end-capped with each tubular labelled as NORM
                        contaminated.
                       Any tubulars contaminated on the outside or with any holes in them will be
                        wrapped in polyethene and transported in a completion skip.
                       The maximum dose rate at any point on the outer surface of the vehicle loaded
                        with NORM shall not exceed 2 mSv/hr2.
                       The maximum dose rate at one meter distance from the outer surface of any
                        vehicle carrying radioactive material shall not exceed 0.1 mSv/hr.
                       The maximum dose rate at the driver's seat shall not exceed 2.5 Sv/hr.
                       After loading, the container will not be opened until it reaches the storage site
                        at Zauliah.
                       All transport of NORM shall be tracked using the NORM Record of Movement
                        Form (Appendix B).
                       The vehicle transporting NORM shall have minimum stop-overs on route to its
                        destination.
                       Each driver of vehicles carrying NORM shall not drive for more than 4 hours
                        without a break and the total working hours shall not exceed 10 hours per day.
                       After unloading, the container is to be checked for contamination before being
                        used again.
                       Normal transport vehicles can be used.




                  2
                      As per MD249/97



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          2.2.4    Storage of Radioactive Material
                   All NORM contaminated items or materials must be taken to the PDO designated
                   storage site in Zauliyah as soon as reasonably practicable. The NORM storage area
                   must comply with the following:

                       The NORM storage areas must be protected with proper fencing and security
                        so that uncontrolled entry is not possible.
                       There must be proper signage (pictorial and written in English and Arabic)
                        around the fence so that the hazards are understood by everybody.
                       A contour of dose rates for the site shall be available through the supervisor.
                       People who are given access to the site are briefed on the location of hazards.
                      The key for access to the site must only be issued to authorised personnel and
                       must be signed out and back into the custodian’s control.
                      The dose rate at the fence ofthe storage facility shall not exceed 1Sv/hr.

                   All items must be labelled and numbered and a record must be kept of all materials
                   on the site. This record must include the identification number, the activity level
                   and the date of arrival.     This record is maintained by the Zauliyah Production
                   Station Operator and Production Supervisor - Bahja.


          2.2.5    Disposal of Radioactive Material
                   Materials which cannot be decontaminated, in addition to the by-products of the
                   decontamination activity (after removal of NORM scales and silts), can only be
                   disposed of into the designated disposal facility.

                   PDO does not have such disposal facilities at present. The only course of action is
                   to store contaminated materials until such time that the MRME issues guidance on
                   disposal of radioactive materials.


          2.2.6   NORM Restricted Areas
                  Any area where the doserate exceeds 2.5µSv/hr from NORM deposits must be
                  designated a NORM Restricted Area. These areas must be clearly sign posted and
                  entry controlled.




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          Appendix A:             NORM Generation Form

          A                                                         JOB DETAILS
          Location
          Description
          ESCC Code
          Permit No.
          Date /Time commenced
          Date / Time Completed

          B                                              MONITORING DETAILS
          Date    Time      Meter No.     Sample /Location Description Counts/Sec              Sign/Ref. Ind.




          SIGNATURES
          APPLICANT              RESP SUPERVISOR          AREA AUTHORITY             PERMIT HOLDER




          NOTES
          1. Box A & B to be completed even if no NORM is found, as evidence of monitoring.
          2. Monitoring to be carried out if fresh scale or fresh surface are accessed and at the end of each
             stage of the job.
          3. Monitoring to carried out with a mini-instrument 900 series mini monitor with type 44A-scintillation
             probe.
          4. The controlled area should be monitored after decontamination and details entered in box B as
             shown.
          5. This form must be completed in addition to any that the contractor may require.
          6. This form must be kept at the station on activity record file.
          7. Include dose rate measurements if contamination meter exceeds 200 cps.
                         Distribution: Original – NORM Generator
                         Copy – IRFP
                         Copy – Area HSE Advisor




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          Appendix B:            NORM – Record of Movement



          MATERIAL SOURCE _____________________________________
          NORM GENERATION FORM # _____________________________
          DATE ________________________________________________
          TIME ________________________________________________
          MATERIAL TYPE ________________________________________
          QUANTITY (Please state Kg/L/Number) _____________________
          ACTIVITY CONCENTRATION (Bq/g or Bq/l) ___________________
          (In case of equipment or Tubular – Please give the contamination Level in cps)

          Dose rate on the surface of the vehicle ______________________
          Dose rate in driver’s cabin ________________________________
          Dose Rate 1 m from the vehicle ____________________________


          List individual pieces of equipment/drums in consignment
              No.                        Description          Concentration (Sv/hr)




          Sign                                         Sign
          Source Generator                             Operator Zauliyah Station



          CC: IRCP for data base entry



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          Appendix C:            Personal Protective Equipment for NORM Handling

          Reference to PPE for NORM handling in this document refers to:

             disposable coveralls
             rubber gauntlets
             rubber safety boots
             safety helmets
             eye protection
             respirator (oral/nasal mask type such as 3M type 9920)




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          Appendix D:             Work Instructions for Handling NORM
                                  Contaminated Materials during Pigging Operations

          General

          Occasionally Naturally Occurring Radioactive Material (NORM) is encountered in pigging
          operations in the form of contaminated scale, which is composed of non-radioactive sulphates
          containing a mixture of radium 226/228 and their daughters.

          NORM may be deposited on the inside of pipelines and/or be found in sludge contained in the
          pipeline.

          Consideration must be given both to the people actually working at pigging who may
          encounter such material and members of the public who may enter the area after the
          completion of operations.

          Operating Instructions

          The main risks from NORM contaminated materials are inhalation and ingestion and
          protective measures must be taken to ensure that neither of these can occur.

          NORM should be assumed to be present in any pigging cleanout operation. Therefore,
          monitoring equipment (Mini Instrument 44A monitor) shall be on site before operations
          commence.

          The following Personal Protective Equipment shall also be available on site before operations
          commence and shall be worn by all personnel who are likely to come into contact with
          contaminated material and equipment at the pigging station:

              white one-piece disposable suits;
              rubber gloves;
              rubber boots;
              safety helmet;
              eye protection;
              respirator (oral/nasal mask 3M type 8835 or equivalent).

          Smoking, eating or drinking shall not be allowed in the immediate area of operations.

          Any cuts, abrasions, etc. shall be covered by a waterproof dressing.

          1.    Before starting a new pigging operation, clear the pig trap of any existing debris or
                sand, making sure that it is not contaminated with NORM before disposing.
          2.    Barrier tape, polyethylene sheeting and protective clothing must be gathered at the
                trap before it is opened. Place polyethylene sheeting beneath the pig trap before
                opening.
          3.    A competent person must be present with a contamination monitor which has been
                checked to be working correctly.
          4.    Care should be taken when opening the pig trap to limit the amount of silt and sludge
                which may fall out. As soon as the trap is opened the debris in the trap must be
                monitored.


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          5.    If the contamination reading is no more than 5cps above background, then proceed as
                normal.
          6.    If NORM is detected, complete a NORM Generation Form (Appendix A). Erect a barrier
                around the site and allow only the minimum required persons in the NORM
                contaminated area to carry out the operation safely. A water tanker and sufficient
                approved drums to hold waste generated must be brought to site.
          7.    All person entering the area must have PPE as specified above.
          8.    A representative sample should be taken and sent to the production chemistry lab for
                analysis.
          9.    The NORM contaminated materials (including polyethylene sheeting) should be put
                into storage drums and mixed with cement.
          10.   The spade used to mix the cement should be washed off into the drum.
          11.   The mixture should then be allowed to set and once the concrete has set, a lid must
                be placed on the drum.
          12.   If only small quantities of debris is present, the same drum can be used until full.
          13.   All collected, drummed contaminated materials must be sent to the Zauliyah Storage
                Site. A NORM – Record of Movement Form (Appendix B) must accompany the
                shipment.
          14.   All personnel leaving the site must wash themselves, their boots and gloves at the
                designated wash area.
          15.   All employees leaving the wash area must be monitored by contamination meter.
          16.   Should it be necessary to have drinking water facilities in the area, disposable cups
                must be provided and these must be only used once.




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          Appendix E:             Work Instructions for Handling NORM Suspect
                                  Materials during Well Engineering and Services
                                  Operations

          General

          Occasionally Naturally Occurring Radioactive Material (NORM) is encountered during Well
          Engineering and Services operations in the form of contaminated scale, which is composed of
          non-radioactive sulphates containing a mixture of radium 226/228 and their daughters.

          NORM may be deposited on the inside of wellheads and tubing/subsurface assemblies pulled
          from wells. It can also be found on wireline equipment that has been downhole for periods
          of time or which has been lowered into the junk sub following milling operations.

          Consideration must be given both to the people actually working on Well Engineering and
          Services operations (well pulling and wireline) who may encounter such material and
          members of the public who may enter the area after the completion of operations.

          Operating Guidelines

          The main risks from NORM contaminated materials are inhalation and ingestion and
          protective measures must be taken to ensure that neither of these can occur.

          NORM should be assumed to be present in any well scheduled for well pulling or wireline
          operations. Therefore, monitoring equipment (Mini Instrument 44A monitor) shall be on site
          before operations commence.

          The following Personal Protective Equipment shall also be available on site before operations
          commence and shall be worn by all personnel who are likely to come into contact with
          contaminated tubulars and/or wireline tools and equipment pulled from suspect wells:

             white one-piece disposable suits;
             rubber gloves;
             rubber boots;
             safety helmet;
             eye protection;
             respirator (oral/nasal mask 3M type 8835 or equivalent).

          Smoking, eating or drinking shall not be allowed in the immediate area of operations.

          Any cuts, abrasions, etc. shall be covered by a waterproof dressing.

          1. All tubulars and downhole equipment and tools shall be monitored by a competent
             person for the presence of NORM as they are retrieved from the well. If NORM is
             detected, complete a NORM Generation Form (Appendix A).

          2. All joints of tubing with contaminated scale or solids inside shall be sealed with end caps
             and labelled with ‘NORM’ tape.

          3. If scale or contaminated solids are present on the outside of tubulars and/or tools and
             equipment, these shall be wrapped in polyethene that shall be sealed and labelled as
             above.

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          4. Any debris (scale, sludge) dislodged from the downhole equipment shall be carefully
             collected and placed in drums together with any solids cleaned from rubber gloves and
             boots, etc. A sample of the solids shall be collected, labelled and sent to the Production
             Chemistry Laboratory for analysis. The contents of the drum should be mixed with
             cement. The mixture should then be allowed to set and once the concrete has set, a lid
             must be placed on the drum.

          5. After completion of operations and rig down, the site shall be monitored to check for
             NORM contamination and any remaining debris collected.

          6. All personnel shall be monitored for NORM contamination as they leave the site,
             particularly the soles of their boots, and any remaining contamination shall be washed off
             ensuring that solids are collected for disposal. As soon as possible after leaving the site
             all personnel must wash their hands, especially before eating or smoking.

          7. All contaminated tubulars, equipment and tools and collected debris shall be dispatched
             to Zauliyah for storage. A NORM – Record of Movement Form (Appendix B) must
             accompany the shipment.

          8. The owner of any contaminated tool/equipment should be notified and discussions held
             with the CRFP to determine the fate of the equipment, i.e., storage, decontamination, or
             disposal.




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          Appendix F:             Work Instructions for Vessel Entry of NORM
                                  Contaminated Vessels

          General


          NORM may be deposited on the inside of vessels, valves, piping and other pieces of
          equipment that has been in contact with NORM containing gases, liquids or solids. It can
          also be found in the sludges that accumulate in the bottom of vessels.

          When doing maintenance on such equipment, consideration must be given both to the people
          actually working on the equipment who may encounter such material and members of the
          public who may enter the area after the completion of maintenance operations.

          Operating Guidelines

          The main risks from NORM contaminated materials are inhalation and ingestion and
          protective measures must be taken to ensure that neither of these can occur.

          Before entering or opening equipment, it must be determined to be free of NORM.
          Therefore, monitoring equipment (Mini Instrument 44A monitor) shall be on site before
          maintenance operations commence.

          The following Personal Protective Equipment shall also be available on site before operations
          commence and shall be worn by all personnel who are likely to come into contact with
          contaminated equipment:

             white one-piece disposable suits;
             rubber gloves;
             rubber boots;
             safety helmet;
             eye protection;
             respirator (oral/nasal mask 3M type 8835 or equivalent).

          Smoking, eating or drinking shall not be allowed in the immediate area of operations.

          Any cuts, abrasions, etc. shall be covered by a waterproof dressing.

                    1.    Prior to starting work, the outside of the vessel should be monitored with the
                          Mini 44A monitor. If readings are 5 cps or more above background then it
                          can be assumed that the material in it will be active and all precautions can
                          be prepared beforehand.

                    2.    Barrier tape, polyethylene sheeting, and the protective clothing must be
                          gathered at the vessel before it is opened.

                    3.    A competent person must be present with a contamination monitor which
                          has been checked to be working correctly.

                    4.    As soon as the vessel is opened the interior of the vessel should be
                          monitored.


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                   5.     If not active then proceed as normal. If active erect a barrier round the site
                          and allow only required personnel into the "controlled area" to carry out the
                          operation safely. A water tanker and sufficient approved drums to hold the
                          waste generated must be on site.

                   6.     Polyethylene sheeting should be placed on the ground having first created a
                          shallow bowl to try to ensure containment of any sludge or other debris from
                          inside the vessel.

                   7.     A drum should be placed under the vessel manhole and the silt/sludge
                          emptied into it.

                   8.     A representative sample of contaminated materials should be taken and sent
                          to the production chemistry laboratory for analysis. A record of the drum
                          into which it is to be placed and the approximate mass (in kg) must be sent
                          with the sample. The NORM Generation Form (Appendix A) must be
                          completed and sent with the sample.

                   9.     The drum(s) containing the waste materials and any other contaminated
                          items (e.g., PPE) should be placed in a secured, temporary storage area until
                          the sample analysis results are received. If the analysis confirms the
                          radioactive nature of the waste, then proceed with cementing operations
                          below and ship the drum(s) to the Zauliyah Storage Site.

                   10.    Cement must be mixed and put into the drum and the mixture stirred to
                          ensure mixing.

                   11.    The spade used to stir it should be washed off into the drum.

                   12.    This mixture should then be allowed to set.

                   13.    Boots and gloves must be washed clean in the controlled area.

                   14.    After the concrete has set the lid should be placed on the drum.

                   15.    If only small amounts of debris are present then the same drum can be used
                          on several occasions until full.

          All personnel must be monitored as they leave the area, particularly the soles of their boots.
          As soon as possible after leaving the area they must wash their hands. Should it be
          necessary to have water drinking facilities in the area disposable cups must be provided and
          these must only be used once. Gloves must be removed and hands washed in the controlled
          area before drinking.




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