100% Canadian Owned

HANDLING OF RADIOACTIVE FRAC SAND

REGULATIONS

The Canadian Nuclear Safety Commission regulations for disposal of sand labeled with a radioactive prescribed substance are as follows:

 “Contaminated sand to be buried at the worksite under at least 30 centimeters of soil provided that the specific activity is less than 370 kBq per kilogram of sand.”

 “Any other waste disposal method will require specific written approval to the Canadian Nuclear Safety Commission.”

INTERPRETATION

The above regulation refers to “370 kBq of activity” which is the equivalent of 10 microcuries (uCi) of Iridium 192, Scandium 46 and Antimony 124 per kilogram of frac sand.  This amount translates into 10 millicuries per tonne of sand which is considerably higher than the amount injected per tonne (1 mCi/Tonne).

CONTAMINATION MONITORING

Returned sand can be assumed to be contaminated and buried as per instructions below under “Burial of Sand”

R.A. Tracer will return to the location to monitor returned frac sand, prepare a contamination survey report and provide instructions on the steps that must be followed to safely satisfy regulation requirements.  An additional fee will apply for this service.

 All monitoring performed by R,A, Tracer will be with the use of a Ludlum pancake monitor.  The following calculations have been made for this specific instrument to correspond with necessary actions that need to be taken.  The recorded level and action required are as follows:

BURIAL OF SAND

1. Once the sand has been recovered in it’s entirety, the oil company must request that R.A. Tracer monitor the returns to establish the level of contamination and supervise the cleanup to satisfy CNSC regulations.

2. The following actions should be taken to limit the amount of hydrocarbons in the sand to be buried:
1. Pump a sufficient amount of water into the tank to displace the hydrocarbons out of the sand.
2. With the use of a vacuum truck , skim the hydrocarbons out of the tank.  Care should be taken to ensure that none of the sand is inadvertently picked up.
3. Dispose of the hydrocarbons in normal fashion.

3. The sand/water mixture can now be removed from the tank and buried on the lease.  The pit for burial should be excavated first and be deep enough to allow a minimum of 30 cm. of soil cover.  The sand can be removed with the use of a vacuum truck or manually shovelled into a pit.  The following safety tips should be adhered to during this operation:

During clean-out:

1. Wear protective clothing (gloves, coveralls and boots).
2. Cover all open skin, abrasions and cuts.
3. Keep hands away from mouth and nose (no smoking/eating).
4. Avoid spreading contaminated sand around lease.

Following clean-out:

a.      Rinse tools used in clean-out with water.

b.      Dispose of gloves used in clean-out.

c.      Wash hands in warm soapy water.

UNDER NO CIRCUMSTANCES CAN THE CONTAMINATED SAND BE TAKEN TO A RECYCLING FACILITY.