Costs of Managing NORM

1. Costs of Managing NORM Brett Young

2. Infrastructure • Replacement of contaminated equipment • Xmas trees, esp’s, tubulars, valves, pumps • Dedicated NORM Storage facility • Interim storage areas (Other locations) • Decontamination facility (fixed/mobile) • Long term disposal options • (Shallow burial/deep well/bioremediation) • Transportation of contaminated equipment

3. Administration • Specifications e.g. PDO SP 1170 • Guidelines or Local Rules • Development/Review of NORM mgt system • Review and renewal of contracts (V.o.C.) • Hoists/rigs, pigging, tank/vessel cleaning, plant maintenance, NORM & WTF Management • Contractors implementing Corporate NORM Mgt system into their HSE mgt systems • System Audits/inspections (Contract Holder and Company self assessments/audits)

4. Identification, Assessment and Control, Recovery • NORM meters - 3 types required • Each asset & various contractors • Activity Analysis e.g. sludge/sands/wax • PPE • Medical surveillance

5. Human Resources • CRFP or SRPS • RPS • RPT’s • External consultants e.g. RPA • Training • 5000 Awareness @ 1 hour = 5000 hrs • 200 RPT @ 4 hours = 800 hrs • 20 RPS @ 2-3 days = 480 hrs Total = 5880 hrs or 735 days

6. Examples • Production losses • Well head closed for 2 months (150m3/day) • Well closed for 3 weeks (300 m3/day) • Hoist and camp moved • Tanks not emptied for nine years • Known to contain NORM • Then delays with NORM storage facility • Confusion as to how to transport/store the sludge • Unable to collect sample prior to emptying tank contents

7. Hidden Costs • Meetings/Correspondence • Radiation Advisory Committee • Emails/phone calls/Advice and assistance • Morale - fear of exposure, uncertainty • Failing to comply with systems • Legal Responsibility & Moral issues • Health of Workforce • Occupational Illnesses (lung cancer) • Loss of income earner • Reputation