COMMUNIQUE
NATIONAL WORKSHOP ON THE ABANDONMENT OF IONIZING RADIATION SOURCES IN OIL WELLS AND THE ISSUE OF NATURALLY OCCURING RADIOACTIVE MATERIAL (NORM) ARISING FROM WELL LOGGING OPERATIONS, 24TH MAY 2011, ABUJA –NIGERIA
1. The Nigerian Nuclear Regulatory Authority (NNRA), organized a 1-day National Workshop on the Abandonment of Ionizing Radiation Sources in Oil Wells and the Issue of Naturally Occurring Radioactive Material (NORM) Arising from Well Logging Operations on 24th May 2011 at Rockview Hotel, Abuja.
2. The Opening Ceremony of the Workshop was chaired by the Honourable Minister, Federal Ministry Petroleum Resources, represented by
3. The Director-General/Chief Executive Officer of National Environmental Standards and Regulations Enforcement Agency (NESREA) was the Special Guest of Honour while the outgoing Director-General/Chief Executive Officer of the NNRA Professor Shamsideen Babatunde Elegba delivered Good Will message at the Opening Ceremony.
4. The Acting Director-General/Chief Executive Officer of the NNRA Mr. Bulus Nkun Yabaya was the Chief Host. Also in attendance was Managing Director of Schlumber Nigeria Limited Mr. Andrew Olotu
5. Representatives of Department of Petroleum Resources (DPR), Nigeria Atomic Energy Commission (NAEC), Energy Commission of Nigeria (ECN), NESREA, NNRA staff, Executives of Oil and Gas Companies Service Companies and Well Owners also attended the Workshop.
6. The Workshop underscored the important role of Oil and Gas companies on the Abandonment of Radiation Sources in Oil Wells and the Issue of NORM Arising from Well Logging Operations in the country.
7. The Workshop underline the need to share experience and develop strategies for the enhancement of the efficacy of the use of radiation sources in well logging operations in order to reduce the incidence of loss of control of radiation sources in well logging operations and inappropriate dumping of NORMS arising from well logging operation by minimizing or eliminating radiological incidents thus the subsequent environmental impact of well logging activities in the country.
8. The Workshop expressed satisfaction with the efforts of the NNRA in providing the forum to relevant stakeholders in the country to address the issues of Abandonment of Radiation Sources in Oil Wells and NORM Arising from Well Logging Operations
9. OBSERVATIONS
At the end of the 1-day successful deliberations, the Workshop observed:
(i) that abandonment of radioactive sources in oil wells is a case-by-case issue;
(ii) that one reason for abandonment may be due to cost of operating, from the point of view of the major operating companies as well owners or operators think that it could be cheaper or more cost effective for them to simply bury a logging tool (BHA + Radioactive Source) without trying further in their attempt to fish and simply pay for it;
(iii) that there is the need to review well logging procedures to identify factors responsible for abandonment particularly in terms equipment (tools) age, technology, personnel training and environmental factors as most causes of loss in hole can be prevented through good planning;
(iv) that there is the need for NNRA to review its abandonment licence processes through increasing the penalty and on the spot witnessing the whole abandonment processes at the expense of the well owner;
(v) that abandonment of radioactive sources in Nigeria is much more that the world average and even more than that of Indonesia, Malaysia, Mexico, etc;
(vi) that Abandonment is a challenge and no service company will want to abandonment the radioactive sources as its tool is lost as well.
(vii) that when stuck in hole fishing company must be more efficient in trying to retrieve the radioactive source
(viii) and knowing the terrain you are working, what overbalance that is available, the mud must be very good and above all good drilling practices. It must also be ensured that the BHA should not be allowed to rest in one position for too long
(ix) that there are abandonment cases that cannot be prevented. Some may be human error, security situation in the country especially in the Niger Delta
(x) that there is the need for all stakeholders to come together to reduce the incidences of loss in holes
(xi) That environmental factors such as geology is an important factor
(xii) that the type of mud use in drilling - the use of water based or oil based board, also determines the probability of getting stuck
(xiii) that most drillings are going deeper now and the information available on these formations is limited. This information is also crucial when testing a new technology and will affect the incidence of stuck in hole
(xiv) that risk mitigating development component from service companies are sometimes rejected by the well owners on the basis of high cost
(xv) that the issue of loss in hole of radioactive sources needs to be looked at in a more holistic manner by the industry regulators (NNRA, DPR, NAPIMS), the service companies and the Operators
(xvi) that poor fishing equipment quality and maintenance are also responsible for cases of loss of radioactive sources in hole
(xvii) that some service providers though passed pre-qualification but failed at the point of mobilization
(xviii) that the biggest problems in oil and gas is human resources, therefore, there is the need for a deliberate programme of training and retraining of personnel involved in well logging operations
9. RECOMMENDATIONS
The Workshop recommends that:
A. Federal Government
Should provide adequate funding to the NNRA to discharge its statutory responsibility in order to ensure protection of life, health, property and environment
Should provide adequate security and create enabling environment for regulatory bodies and oil and gas companies to function effectively and safety
Overlapping functions between MDAs (e.g. NNRA, DPR, NESREA, FME, NAEC etc) should be identified and there should be collaborative efforts between these organizations to ensure that cross-sectional issues are resolved
B. NNRA
(i) should establish clear communication lines with operators and other relevant stakeholders in the area of emergency preparedness and response
(ii) should come up with the number of fishing attempts to be made when a radioactive source is stuck in hole before abandonment becomes the last option
(iii) should be on site as soon as there is incidence of stuck in hole and should be able to continues to be onsite until all fishing and abandonment processes are completed. The cost of logistics for the NNRA to the site should be paid by the well owner
(iv) should increase the current fee for abandonment of radioactive sources in hole in order to discourage and minimize the frequency of the incidence
(v) should request all Service Companies/Well Owners to submit reports on the cases of loss of radioactive sources in hole in the last 10 years
(vi) Should ensure the accreditation of not less than three service providers in each of the service area
C. Well Owners
(i) Should ensure that abandonment of radioactive sources in oil wells are carried out in accordance with Nigerian Radiation Safety in Well Logging Regulations, 2008 and international best practice
(ii) Should ensure full compliance with the provisions of Nigerian Well Logging Regulations and NORM Regulations
(iii) Should ensure that only NNRA accredited service providers are engaged. The service providers should have adequate procedures, trained personnel and relevant equipment to carry out NORM monitoring
(iv) Should establish a monitoring programme for facilities and equipment contaminated with NORM in order to ensure that the limits are not in excess of the levels set forth in the NORM Regulations
D. Service Providers
(i) Should ensure full compliance with the provisions of Nigerian Well Logging Regulations and NORM Regulations
(ii) That there is the need to keep abreast with modern practices that reduces the incidence of loss in hole. The operators must also have well trained staff which should also be subject to re-training.
(iii) Should ensure a case-by-case examination of the incidences of stuck in hole so that lessons learnt can be used to prevent and mitigate future occurrences
(iv) Operational procedures should be periodically reviewed to improve on past practices. Emphasis should be on equipment, personnel, procedures etc.
(v) Should collaborate well owners especially on information required for drilling
(vi) should invest more in research and development in order to see if there are better alternatives to technology with prevalent loss of source in hole
Martin Oshof Ogharandukun (Ph.D.)
Acting Director-General/CEO
