NORM Incident Report

REPORTING DEPARTMENT: UWN DATE OF INCIDENT : 21- 28 / 06 / 2010

TIME OF INCIDENT :
INCIDENT LOCATION : Saih Rawl CONTROLLED BY : [ X ] PDO DSV on-site
Well # SR-149 and SOS Inspection Yard Fahud [ X ] CONTRACTOR
PDO INCIDENT SEVERITY (0, 1, 2, 3, 4 or 5) : [ ] THIRD PARTY
[ 1 ] REPUTATION [ 1 ] HARM TO PEOPLE
[ 1 ] ENVIRONMENT
[ 1 ] OVERALL Potential Risk Rating PER1E (Low)
ACTIVITY AT TIME OF INCIDENT BROAD TYPE OF INCIDENT
[X] Handling Hazardous Materials (NORM) [ X ] Unsafe Act/Condition
PARTIES INVOLVED
PDO DEPARTMENT / SECTION: UWN PDO CUSTODIAN : UWN2
CONTRACTOR 1 / CONTRACTOR 2: CONTRACT NUMBER: ??
1: Shivani LLC 2. SOS TOTAL No. POTENTIALLY EXPOSED: 6 - 8

HOW THE INCIDENT OCCURRED

The Qarn Alam Asset requested a workover of SR-149 which utilises gas lift to aid oil production. This
well has been in operation for over 8 years and according to EDM this was the first workover. The gas lift
line and producing oil line were disconnected by the ODC contractor Galfar Engineering. The workover
was performed by Shivani WPH21 who advised that NORM measurements were conducted as per the
procedure and no NORM was detected above background. Consequently, all of the downhole equipment
removed by the WPH was transported to the Special Oilfield Services (SOS) Inspection Yard in Fahud
between 25 - 27 June for scrapping.
On the 27 June SOS reported 56 of 83 joints delivered were NORM contaminated when monitored with a
calibrated Mini 900/44A (Gamma & high energy beta) contamination meter. This was the last batch from
the hoist and was delivered late Friday evening on 25 June 2010. NORM contamination between 20 -100
cps was detected on 56 joints whilst the 27 showed contamination below the PDO NORM limit. SOS
notified the hoist and PDO representatives of the contamination which prompted this investigation.
In total 300 joints, 5-6 gas lift mandrels and other associated equipment including the seal assembly
were delivered to the SOS yard. The equipment were stockpiled in different locations within the yard
awaiting monitoring and/or scrap. None of the joints or mandrels had end-caps/covers during the
transport loading/unloading at the SOS yard as they were all scheduled for scrap. Once NORM was
detected SOS staff end-capped and segregated confirmed joints with NORM tape.
INVESTIGATION
On Monday 28 June, PDO Snr Well Engineer Maarten Van Den Wildenberg UWN2, Field
Superintendant Sean McGurk UWN19 and Industrial Hygienist Brett Young MSE32 visited the hoist and
conducted an investigation with the Shivani Rig Manager (RM) George Runjan and PDO Drilling
Supervisor (DSV) Ibrahim Al-Suleimani.
During the interviews the RM advised he conducted monitoring of the Xmas tree, first five joints and
every 5th joint to the assembly and did not detect NORM using either the Mini 900/44A or Mini 900/EP15
contamination meters. Monitoring at night was conducted by the NTP and there was some suggestion
that the final 83 joints pulled at the night shift may not have been monitored by the NTP and the NORM
was only present in the lower section of the well. This was subsequently found not to be true. The RM
advised he did not monitor the internals of the flowlines and did not receive any indication of NORM from
the ODC contractor who disconnected the flowlines or the Well handover Form provided and signed by
the Asset. The PDO DSV advised he observed the RM take NORM measurements, but he did not take
any measurements himself.
The RM completed the NORM Survey Form Appendix A of SP1170 indicating internal and external
results of 0.2 cps or background with both meters and NO NORM DETECTED. He arranged for the joints
to be transported to the SOS yard for scrap. (Note: background with the Mini 900/44A is 2-3 cps)
On-site, the RM was asked to demonstrate how he assesses the performance of the NORM meters and
to describe how he performs the measurements. The meters were observed within calibration and
appeared in good working condition. However the Mini 900/44A had two layers of polyethylene plastic to
protect the aluminium window from damage during monitoring. During the interviews, the RM was able to
correctly describe the definition of NORM, but could not describe how to measure background levels i.e.
the inside of a clean joint of similar thickness. The RM advised he takes the cap off the Mini 900/EP15
(alpha / beta meter) which is mandatory as the cap will shield any particles giving false readings.
The RM has undertaken NORM Awareness training with NTI and advised he received training on the
WPH by the PDO trainer (Ibrahim Awad) in 2009. (Note: the RM, NTP, Driller and AD shall undertake
NORM for Supervisors. All remaining crew shall undertake NORM Awareness as per SP1170 and
SP1157 HSE Training requirements).
The RM and investigation team utilised the WPH meters to monitor the internals of the flowlines. All other
equipment had been removed to the SOS Yard. The oil line when monitored with the WPH Mini 900/44A
and detected 15 cps with the heavy duty plastic on and 30 cps when removed. This immediately
confirmed the presence of NORM above the PDO limits (5 cps above background). The oil line when
monitored with the WPH Mini 900/EP15 (detects alpha/beta particles) read 30-50 cps, confirming the
presence of NORM. In addition, the investigation team brought an alternate contamination meter - T201
(detects alpha/beta particles). This meter is comparable with the Mini 900/EP15 and it also confirmed the
presence of NORM 30 cps which implies the hoists meters worked correctly. The background was 0.35
cps with the T201, similar to the Mini 900/EP15.
Internal monitoring of the gas lift line using the WPH meters detected 2 cps with the Mini 900/44A and 0.5
cps with the Mini 900/EP15 which is equivalent to background. This indicated that the NORM
contamination came from the producing reservoir.
The change in detection from the Mini 900/44A with the thick plastic (15 cps) and no cover (30 cps) can
be explained by the 2 layers of plastic shielding the high energy beta particles. The scale was very thin in
the oil line, barely visible. If the scale had been thicker, the beta particles would have been self absorbed
by the scale and only gamma photons would have been detected by the 44A probe. However as the scale
was so thin, beta particles were able to escape and were detected by the 44A meter with the cover off. In
the case of thin scales a more accurate measurement can be detected by removing the protective cap or
plastic off or by using only thin plastic to protect the probe during monitoring.
What can be certain is that the WPH RM, NTP or others who performed NORM measurements did not
do so correctly. The erroneous results recorded on the NORM Report Form indicating 0.2 cps indicates
that the RM and NTP do not know how to correctly monitor for NORM and how to interpret results. The
observed monitoring technique of the RM to monitor the internals of the flowlines was poor. The RM did
not orientate the probe towards the scale and was observed placing it straight in which may underreport
contamination. Whilst the DSV advises he witnessed some NORM measurements taken, he too was not
competent to verify if the monitoring was performed correctly.
SOS YARD INVESTIGATION
On 28 June UWN19 and MSE32 visited the SOS yard. NORM measurements were conducted on the
interior of the joints removed from SR-149 using both the Mini 900/44A and T201 as SOS does not have
an equivalent Mini 900/EP15.
From the final 83 joints delivered by the hoist were monitored by SOS, it was reported that only 56 were
contaminated above the PDO Limit i.e. 5 cps above background. Monitoring conducted in the presence
of the investigation team showed all joints were contaminated approve 20 – 100 cps. The SOS staff were
taking the readings to casually and were not orientating the probe window towards the scale.
When monitored with the T201, the joints measured 30 cps confirming NORM contamination. SOS were
requested to collect the gas lift mandrels and other supporting down hole equipment including the seal
assembly. The equipment was monitored internally with the Mini 900/44A and T201 and all showed
elevated NORM contamination above the PDO acceptable limits. Internal measurements of the
mandrels showed 40-90 cps with the T201 and background externally. This further supported that the
gas flowing down the annulus, into mandrels to lift the oil was not NORM contaminated. If this was the
case, the gas flowline and exterior of the joints and mandrels would have tested positive for lead-210
with the T201. What was observe was that some joints had thin black scale which was broken in to
approx 1 cm flakes whilst the mandrels had a thicker observable scale. Photos were taken of scale and
samples will be collected once the joints reach the Bahja NORM yard for analysis to confirm the Radium-
226, Radium-228 and Lead-210 activity.
There was some suspicion or concerns raised that when the joints are wet as during a workover, the
readings are not as accurate owing to shielding of the water/oil giving false negative results. Dirty water
was splashed over 3 joints. The readings with both the Mini 90044A and T201 both showed NORM
contamination indicting that wet pipes or joints if NORM contaminated will still be detected by these
meters as the gammas will penetrate the water. The Beta particles should be shielded from thick scales
and any detection would be predominately gamma, however when wetted on thin scales, both meters
detected contamination comparable to dry scales dispelling the above concerns.
ODC CONTRACTOR GALFAR ENGINEERING
The ODC contractor did not perform NORM monitoring of the gas lift and production flowlines (externally
and internally) when disconnecting them from the Xmas tree. Had monitoring been performed the ODC
Contractor would have detected NORM in the oil producing line (30-50 cps) which would have classified
the well as NORM contaminated. Exposure to NORM scales through inhalation/ingestion would have
been minimal as the scale was very thin and fixed to the spools. Monitoring on site on the 29 June
showed the oil line from the Xmas tree to the choke and ESD line as contaminated. The gas line did not
indicate NORM contamination. SP1170 requires monitoring for NORM of all equipment that has
conveyed or stored production fluids and if potential for inhalation of ingestion exists, workers shall wear
NORM PPE.
CONCLUSIONS
 The ODC Contractor did not take into consideration any NORM precautions.
 The WPH RM and NTP did not monitor the well in accordance with SP1170 or the NORM
Guideline MSE.24 Precautions for Well Re-Entry.
 The NORM meters provided by the hoist were in calibration date and in working condition.
Placing the two layers of thick plastic over the 44A probe shielded some beta particles but not to
background levels as reported by the WPH. Had the EP15 probe been used correctly it would
also have detected the presence of NORM.
OPPORTUNITY FOR IMPROVEMENTS
PDO
1. The Asset Production Supervisor (Responsible Supervisor) did not thoroughly review the ODC
Contractor Job HSE Plan and identify the need to perform external and internal NORM
measurements of the flowlines.
Recommendations:
1a. The ODC Contractor, Galfar Engineering shall be informed by the Contract Holder that
NORM precautions including measurements shall be included during all flowlines to Xmas tree
disconnections. The CH and ODC Contractor shall develop a plan to include NORM training of
Galfar ODC staff, providing NORM meters, or PDO providing in the interim, provision of PPE and
providing NORM monitoring results to the Asset. Note: Likewise if the WPH removes the
flowlines, it shall monitor them for NORM as this represents the first opportunity to detect NORM.
1b. All Production Supervisors shall undergo the NORM Supervisors Course to recognise where
NORM may occur and the precautions to follow in the PtW.
2. The Asset prior to handing over the well to the Hoist Contractor did not identify NORM in the
Well Handover Form. This was left blank. The Asset is responsible for advising/reporting all HSE
risks associated with a well including high pressure, H2S, NORM etc. As this was the first
workover of this well, no prior NORM results exists, however the Asset has not identified if
 similar wells in the same reservoir which underwent a recent workover were NORM
contaminated. This may have given a pre-warning to the WPH and DSV to be more vigilant.
Recommendations:
2a. The Asset (Production Supervisor/Operator) shall obtain the NORM results from the ODC
contractor once the flowline(s) have been disconnected. In addition, NORM results from previous
workovers or interventions shall be used to predict if NORM is likely to occur in the well prior to
being worked over. The PT can include this data in the well proposal. The NORM results shall be
entered in the Well Handover Form by the Asset Production Supervisor/Responsible Authority
prior to handover to the WPH or other service provider.
2b. The Asset shall place NORM contaminated labels on well SR-149 and flowlines. The highest
NORM readings shall be entered into EDM and the Assets NORM Spreadsheets shall be
updated.
3. The Drilling Report requires the Hoist to monitor for NORM. The Drilling Report is explicit about
what to monitor and advises to monitor the Xmas tree, hanger, first 5 joints and every 5 joints
from then on unless NORM is detected. However, it does not advise to monitor the internals of
the flowline(s) which would have indicated NORM at the outset. If the RM, NTP and DSV had
referred to the Flow Diagram in MSE.24 Radiological Safety Precautions for Well Re-Entry in the
NORM Manual, it mandates this requirement.
Recommendations:
3a. Senior Well Engineers to include a line in the Drilling Report for the hoist to refer to the ODC
contractors NORM result and to conduct their own NORM readings of the internals of the
flowlines. The DSV shall verify NORM readings are conducted of the internals of the flowlines in
accordance with SP1170 and NORM Guideline MSE.24.
WPH
Recommendations:
4. The hoist can place a thin layer of plastic over the meter to protect the Mini 900/44A probe and
shall not use two layers of thick plastic. No cover or cap shall be placed on the Mini 900/EP15.
5. Shivani shall develop a plan to train their staff for NORM as per SP1170 and SP1157 i.e.
including NORM Awareness (Crew), NORM for Supervisors (RM NTP, A, AD) and NORM Meter
Users (RM NTP, A, AD).
SOS
Recommendations:
6. Nominated NORM Meter users shall undergo the new NORM Meter training course when
available through NTI.
7. SOS shall be provided both the 2 x Mini 900/44A and 2x Mini 900/EP15 meters
8. All the NORM joints from SR-149 shall be end capped. The Mandrels shall have 200um plastic
taped over the open ends. All the equipment shall be itemised, recorded in Appendix B of
SP1170 and transported to the Bahja NORM Yard for decontamination.

COST INCURRED AS A RESULT OF THIS INCIDENT (US$) : < 10,000

PROPERTY DAMAGE: Nil PRODUCT LOSSES : Nil

................................. ..................................................... ......................................

Brett Young Maarten Van Den Wildenberg Sean McGurk
Industrial Hygienist MSE32 Senior Well Engineer UWN2 Field Superintendant UWN19