TOTAL E&P DENMARK B.V. Nyhavn 43, 2 DK-1051 København K ...

28. april 2015

j.no. 1-5314-20/1/

Reference KRB

T 44543463

E [email protected]

TOTAL E&P DENMARK B.V.

Nyhavn 43, 2

DK-1051 København K

Denmark

License for management and temporary storage of NORM

Pursuant to § 1 of Act no. 94 of 31 March 1953 on the use of radioactive sub-

stances, the Danish Health and Medicines Authority / National Institute of Ra-

diation Protection hereby issue license for management and temporary storage

of Naturally Occurring Radioactive Material (NORM), which is produced in

connection with the establishment of the exploration well "Vendsyssel-1" at

Dybvad, as described in your application of 14 April 2015 and in the pertinent

radiation protection plan: SSP HSE 06.01 revision 1.

The license is granted on the following conditions:

• Responsibilities and management of NORM as well as eventual NORM con-

taminated water and drilling mud must be executed in accordance with the radi-

ation protection plan [SSP HSE 06.01 revision 1] dated 14 April 2015.

• In addition to the above, all management etc. of NORM must be in accord-

ance with the "Guidelines on the management of NORM in the oil and gas in-

dustry", National Institute of Radiation Protection, 2005 (“Vejledning om

håndtering af NORM fra olie- og gasindustrien, 2. Udgave, 2005”).

• The current radiation protection regulations in Denmark must be observed.

• The license is revoked should the RPO transfer or resign his position without

the reassignment of the responsibilities to a new RPO previously notified to and

approved by the Danish Health and Medicines Authority / National Institute of

Radiation Protection.

The license is valid until 31 December 2015.

Yours sincerely,

Kresten Breddam

Chief Advisor

Site Specific Procedure

Company Management System

RADIATION PROTECTION PLAN

SSP HSE 06.01 04/15 Rev : 1 Page 1 / 40

This document is the property of Total E&P Denmark. It must not be reproduced or transmitted to others without the written Company’s authorization.


1 04/15 After SIS review

0 02/15 Issued to SIS for review

Revision Date Main modifications

Approbation :

Rev Date Prepared by Verified by Approved by

1 04/2015 A. RIOU

Head of Subsurface

A. JOATHON

Head of Drilling

P. TALLONE

Operation Manager

Only the electronic version is updated, before any use the current version of this document shall be verified on the Intranet network.




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Table of Contents

1. OBJECTIVE .............................................................................................................. 5

2. APPLICATION .......................................................................................................... 6

3. REFERENCE DOCUMENTS .................................................................................... 6

4. General information ................................................................................................ 7

5. RESPONSIBILITIES ................................................................................................. 8

5.1 Responsible for Safety and Environment on Site (RSES) ................................................. 8

5.2 Wellsite Geologist (WSG) .................................................................................................. 9

5.3 Radiation Protection Officer (RPO) .................................................................................... 9

6. Vendsyssel-1 well information ............................................................................. 11

6.1 General data .................................................................................................................... 11

6.2 Alum Shales objective ..................................................................................................... 11

6.3 Reference wells ............................................................................................................... 12

7. Specific source of radiation – risk assessment ................................................. 12

7.1 Formations involved ......................................................................................................... 12

7.2 Technical risk ................................................................................................................... 13

7.3 Amount of formation ........................................................................................................ 13

7.4 NORM amount evaluation ............................................................................................... 14

8. NORM definition and alert level ........................................................................... 15

8.1 NORM definition .............................................................................................................. 15

8.2 Secular equilibrium .......................................................................................................... 16

8.3 NORM alert levels ............................................................................................................ 16

9. Monitoring MEASURES ........................................................................................ 18

9.1 Measurements on cuttings while drilling .......................................................................... 18

9.2 Measurements on cores while drilling .............................................................................. 19

9.3 Measurement on Mud while drilling ................................................................................. 19

9.4 Environmental monitoring ................................................................................................ 19

10. NORM level verification and handling ................................................................. 20




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10.1 NORM level verification ................................................................................................... 20

10.2 NORM handling and disposal .......................................................................................... 22

11. Reporting ............................................................................................................... 24

11.1 Internal reporting .............................................................................................................. 24

11.2 External reporting ............................................................................................................ 24

12. APPENDICES ......................................................................................................... 25

12.1 Appendix 1: RPOs ........................................................................................................... 25

12.2 Appendix 1: VDS001 – amount of formation involved ..................................................... 28

12.3 Appendix 1: Offset wells XRF analysis results ................................................................ 30

12.4 Secular equilibrium .......................................................................................................... 31

12.5 NORM alert levels ............................................................................................................ 32

12.6 Monitoring equipment specifications ................................................................................ 34




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Glossary

DGEP Direction Générale de l’Exploration Production

E&P Exploration et Production – Exploration and Production

HSE Hygiène Sécurité Environnement – Heath Safety Environment

µSv micro Sieverts (a unit of radiation dose)

Bq Becquerel (The SI unit of radioactivity, 1 Bq being equal to one atom in a given substance undergoing transformation each second)

Bq/cm2 Becquerel per centimeter squared (A unit of radioactive contamination, 1 Bq/cm2 being equal to 1 Bq being present on each cm2 of the surface area monitored)

Bq/g Becquerel per gram (A unit of specific activity, 1 Bq/g being equal to 1 Bq being present in each gram of material analyzed)

CPS Counts per second (The instantaneous unit displayed on a contamination monitor, can be converted into a reasonable estimate of Bq/cm2 if the user has knowledge of the calibration data, isotopes in the material being monitored and the surface conditions of the material)

NORM Naturally Occurring Radioactive Material (A term used in the oil and gas industry to define material that has a higher than normal specific activity)

PPE Personal Protective Equipment (Clothing provided by the employer to minimize potential exposure to a specified hazard)

RPA Radiation Protection Adviser (A recognized expert in radiation protection and the disposal of radioactive wastes, sometimes known as the Qualified Expert (QE))

RPE Respiratory Protective Equipment (Masks, respirators, or similar used to minimize the amount of an airborne contaminant entering into the body)

RPO Radiation Protection Officer (The person appointed to act in a supervisory position for work on site involving ionizing radiation. The RPO will be responsible for identification and measurement of radioactivity and ensuring that controls are put in place to minimize exposure)

TEPDK Total E&P Denmark B.V.




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1. OBJECTIVE Total E&P Denmark plans to drill the well Vendsyssel-1 dedicated to natural gas exploration, in Northern Jutland. The drilling of the well is scheduled to take place in 2015.

Elevated levels of uranium and the equally radioactive decay product radium are naturally found in the Alum shale which is the well’s primary objective. There is relatively limited knowledge of the radioactive content of alum shale.

The threshold above which a natural material containing radioactive substances and decay products must be treated as radioactive is above 0.5 Bq/g for naturally occurring uranium. For natural uranium, 0.5 Bq/g is equivalent to a uranium content of 40 ppm.

During drilling of the Alum shale, the risk of emission of Naturally Occurring Radioactive Material (NORM) is deemed very low; however it is not disregarded.

In accordance with EU Council Directive 2013/59/EURATOM (EU-BSS), the well Vendsyssel-1 is therefore identified as a practice involving NORM.

As such a license is required from the Danish National Institute of Radiation Protection (SIS).

NORM level will be monitored while drilling / coring the Alum shale. This will consist of analysis of the drill cuttings and Gamma Ray (GR) measurements on the cores and on the drilling mud. There is no process water as such that will be generated. There should not be radioactivity in the waste water that will be treated off site as this will be effectively just rainwater. NORM level of the water deriving from the dewatering of the drilling mud, will be monitored through the monitoring of the drilling mud. Cuttings from the Alum shale will be removed ‘wet’ from the well, being drilled with water base mud. Consequently, no generation of dust is expected. Potential NORM levels shall also be monitored on surface soils, surface water and ambient air as part of the environmental monitoring program.

If potential NORM are detected, a specialized company will be mobilized to confirm or not the value obtained by the on-site analysis, through direct measurement.

If the NORM level is confirmed to be above the acceptable threshold for transport and disposal, the NORM will be handled and disposed accordingly by the specialized company. Note that the limit for transport and disposal is far more conservative than the limit that could pose a risk to people.

The SEMCO-Bilfinger joint venture is the specialized company.

The purpose of this Radiation Protection Plan (RPP) is to detail the strategy to monitor the NORM levels while drilling and / or coring the Alum shale on Vendsyssel-1 well as well as to handle the NORM, if its presence is measured and confirmed.

This plan covers: - general information about the companies and the well, - the risk assessment regarding the potential specific sources of radiation, - the monitoring while drilling, - the environmental monitoring, - the means to verify the NORM level through direct measurement, - the procedure to handle the NORM if any, - the reporting during the operation.




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2. APPLICATION The Radiation Protection Plan applies to the drilling and / or coring operations of the Alum Shales formation on Vendsyssel-1 well. Handling and transport of the radioactive waste, if any, is also included in the Radiation Protection Plan, as being part of the scope of SEMCO, the specialized company that would be mobilized if NORM is detected. The procedure described in this document prevents site contamination. Any contaminated item from NORM will be quarantined and handled by SEMCO.

3. REFERENCE DOCUMENTS Unless otherwise stated explicitly, the applicable version of the documents listed below, as well as the annexes and any additives, is the final published version.

Standards

Reference Title

National Institute of Radiation Hygiene

Code of Practice for the Handling of NORM from the Oil and Gas Industry, 2003.

Professional’s documents

Reference Title

International Association of Oil and Gas Producers

Guidelines for the Management of Naturally Occurring Radioactive Material (NORM) in the Oil and Gas Industry, 2008.

International Atomic Energy Agency, IAEA-TECDOC-1712

Management of NORM Residues, 2013.

International Commission on Radiological Protection – ICRP 66

Human Respiratory Tract Model for Radiological Protection, 1994 ICRP Publication 66. Ann. ICRP 24 (1-3)

International Commission on Radiological Protection - ICRP 68

Dose Coefficients for Intakes of Radionuclides by Workers, 1994.

ICRP Publication 68. Ann. ICRP 24 (4).

International Commission on Radiological Protection - ICRP 103

The 2007 Recommendations of the International Commission on Radiological Protection, 2007.

Regulations

Reference Titre

ADR 2013 European Agreement Concerning the International Carriage of Dangerous Goods by Road, 2013.

European Commission - Radiation Protection 88

Recommendations for the Implementation of Title VII of the European Basic Safety Standards Directive (BSS) Concerning Significant Increase in Exposure to Natural Radiation Sources, 1997.

European Commission, Radiation Protection 122

Practical Use of the Concepts of Clearance and Exemption. Part II Application of the Concepts of Exemption and Clearance to Natural Radiation Sources, 2002.




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Organisation for Economic Co-operation and Development, Nuclear Legislation in OECD Countries

Regulatory and Institutional Framework for Nuclear Activities – Denmark, 2007.

Public Health England Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction (Draft for Comment), 2013.

Codes

Reference Titre

Other documents

Reference Titre

Total documents

Reference Titre

CR EP HSE 067 Prevention of health risks due to radiation

GM EP HI 671 Prevention of risks from natural radioactivity

Total E&P Denmark documents

Reference Titre

INS HSE 02 01 Hygiene/Health, Safety, Societal and Environmental (HSE) Charter

SSP HSE 09.01 Site Emergency Response Plan

4. GENERAL INFORMATION Company responsible for the site:

- TOTAL E&P DENMARK B.V. Nyhavn 43, 2 DK-1051 København K, Denmark

Legally responsible person:

- Renaud LIONS




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Total E&P Denmark General Manager Phone: +33 6 09 62 51 06 [email protected]

Contact in Copenhagen:

- Henrik NICOLAISEN Senior Coordinator +45 5339 1031 [email protected]

Site address

- Ovnstrupvej 4, 9352, Dybvad Contact on site

- Daniel POIBLANC / George CRUCHET Total RSES (Responsible for Safety and Environment on Site) +45 5339 2446

Radiation Protection Officer(s) (RPOs);

- The RPO(s) (Radiation Protection Officer(s)) will be personnel of SEMCO, the specialized company contracted to provide NORM services if required

- A pole of personnel has been defined, from which the ROP would be mobilized

Refer in appendices for the list of CVs of the personnel who can be appointed RPOs.

5. RESPONSIBILITIES

5.1 Responsible for Safety and Environment on Site (RSES)

The RSES is the Total E&P Denmark representative on the site for any issue pertaining to HSE, contracted activities included. The RSES must be continuously present on his site. The RSES is the company senior drilling supervisor. The RSES role includes but is not limited to: Risk evaluation, including,

- Technological risk analysis, - Industrial hygiene risk assessment for working and living situations on site in normal,

transient and downgraded situations, - Security risk assessment on site, - Risk assessment for any kind of work on site

Risk management, including,

- Compliance with the HSE instructions, rules and procedures, - Compliance with work and health/ safety conditions necessary for the protection of

persons, - Protection of the environment and monitoring of environmental performances, - HSE reporting: notification and analysis of any incident or anomaly




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Whenever risk management can no longer be satisfactorily ensured, the RSES is authorized to apply any measure he sees fit to recover control and to halt the operations if necessary. Preparedness and management of emergency situations, including,

- Application of the entity’s emergency response plan and related procedures - Communication and consultation with the other actors in the entity involved, as laid

down in the emergency response plan.

5.2 Wellsite Geologist (WSG)

The wellsite geologist shall be the most high-up representative of the affiliate’s Geosciences entity at the wellsite. The wellsite geologist shall report directly to the affiliate’s head of Subsurface entity. However, the site RSES remains, at all times, the leading Company representative at the wellsite. The wellsite geologist will be in charge of the NORM monitoring during the drilling / coring activities, reporting directly to the site RSES on this matter. The WSG role includes but is not limited to:

- Contribute to the safety of operations the integration and interpretation of real time data,

- Guarantee the pertinence, reliability and quality of the data acquired in wells. - Responsible for the quality of all data acquired, - Ensures supervision, coordination and/or realization of all geological surveillance

tasks such as cuttings descriptions - Supervises and ensures regular testing and sensors calibration of Mud Logging

equipment - Participates actively, through the interpretation of all available data, in the

identification and evaluation of drilling hazards - Informs at anytime the drilling supervisor on site and Subsurface Entity at the base of

any new real time data input that can improve drilling operations efficiency and safety.

5.3 Radiation Protection Officer (RPO)

A Radiation Protection Officer (RPO) shall be appointed from the specialized company.

The Radiation Protection Officer must have a basic knowledge of radioactivity and radiation, practical radiation protection and relevant Danish legislation. The person concerned must be able to measure and evaluate the radiation conditions and, if necessary, take the appropriate radiation protection measures.

The RPO must ensure that the handling of NORM is only dealt with by persons who have received instructions about the work and the related risk to health, as well as the safety measures that are to be implemented to prevent such risks.




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The RPO must ensure that the relevant measuring instruments and screening equipment are available for the work and that such instruments and equipment are used properly. The measuring instruments must be checked and calibrated regularly.

The appointed RPO(s) will have attended a suitable, assessed RPO training course.

The RPO role also includes (not limited to),

- Ensure that all hazards related to work with ionising radiation are identified and where appropriate, risk assessed and also that suitable precautions are taken to minimize the risks associated with these hazards.

- Ensure that all work involving ionising radiation is carried out in accordance with the relevant Local Rules.

- Maintain a full and up to date record of all radioactive materials on the site that are under his/her control.

- Ensure that NORM checks are carried out on all equipment / systems that have the potential to contain NORM prior to any maintenance involving breaking of containment,

- Ensure annual NORM waste disposal records are submitted, - Assume other relevant responsibilities as requested but not detailed above, to ensure

that the company’s responsibilities under the relevant radiation legislation are addressed

The RPO will be in charge of the verifying that the NORM is handled, transported properly

Procedure in place prevents site contamination. However, any contaminated item from NORM will be quarantined and handled by the SEMCO, supervised by the RPO




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6. VENDSYSSEL-1 WELL INFORMATION

6.1 General data

Exploration Well Vendsyssel-1 (VDS-001) will be the first well dedicated to shale gas in Denmark and is located in North Jutland.

Block: Nordjylland 01/10 License Operator & Partners:

o 80 %Total E&P DK (Total E&P Denmark B.V. operator) o 20% Danish North Sea Fund (Nordsofonden)

Well Profile: Vertical Drilling Rig: SMP-105 Well primary objectives: Alum Shales Surface coordinates (as measured at the end of the Civil Works by GeoPartner):

o Easting = 576 460.3 m o Northing = 6 349 736.61 m o GL = + 21,35 m/MSL

VDS-001 well is located 30 km from Fredrikshavn, 42 km from Alborg, 265 km from Esbjerg and 459 km from Copenhagen.

6.2 Alum Shales objective

The Alum Shales objective will be drilled / cored during the 8-1/2" phase.

This objective will be crossed from about 3610 to 3740 m TVDSS, corresponding to an expected thickness of 130 m.

Rate of Penetration (ROP) expected for the drilling and / or coring of the Alum shales is from 1m/hr to 3m/hr




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Depending on the actual ROP as well as on the actual quantity of BHAs (Bottom Hole Assemblies) - drilling or coring – required to drill / core the 130m, 10 to 15 days are estimated for crossing the Alum shales.

6.3 Reference wells

Despite a great number of wells drilled onshore and offshore Scandinavia very few of them only crossed the Alum Shales formation which is the main objective of Vendsyssel-1 well (VDS001). Uranium measurements from X-ray fluorescence (XRF) analysis are available for three (3) of those offset wells: Terne-1, Sommerodde-1 and Albjara-1.

6.3.1 Terne-1

This well drilled in 1985, is the nearest well (about 135 km) crossing the Alum Shales from the VDS001 well location.

The Alum Shales section was not cored but covered by a quite complete set of wireline logs and an extensive set of analyses done on cutting.

Terne-1 is the nearest well from VDS001 and considered as the best offset for the Alum shales. The results from Terne-1 well are therefore considered as the most relevant for VDS001 prognosis.

6.3.2 Sommerodde-1

Located on the Bornholm Island, Sommerodde-1 is the latest scientific well (2012) drilled by the GEUS in this formation.

The well was integrally cored and a full set of wireline logging was acquired at TD.

Despite its location (more than 400 km from VDS001) and different deposit environment, it remains an important reference for the pre-drilling studies as it offers a rich source of "fresh" samples from cores and an "extreme" limit for the Alum Shales deposit in Denmark (very condensed series, more confined environment during deposit).

6.3.3 Albjara-1

Located in the southern part of Sweden, this well was drilled in the 90's and the Alum Shales was partially cored.

It represents an intermediate reference between Terne-1 and Sommerodde-1 in term of condensation of the series but remains in the same confined deposit environment than Sommerodde-1.

7. SPECIFIC SOURCE OF RADIATION – RISK ASSESSMENT

7.1 Formations involved

Considering the logs of the reference wells, the only formation crossed on Vendsyssel-1 well presenting significant Gamma Ray values are the Alum Shales with the highest values located in the upper half of the formation.




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This activity is linked to the Total Organic Content (TOC) where Uranium from organic sediments is concentrated and trapped during the deposit of the formation.

The RPP will therefore be in place for the drilling and / or coring of the Alum Shales, planned in the 8 ½’’ section.

7.2 Technical risk

During the drilling/coring phase there is no means of concentrating any natural activity and so radioactivity can only be issued by the natural radioactivity of the cuttings.

Drilling mud may be contaminated with fragments from the cuttings and cores; this means that the maximum specific activity will be less than the cuttings themselves.

.

7.3 Amount of formation

Only drilled out formation is considered as a potential hazard during the drilling phase. The Alum Shales will be drilled / cored during the 8-1/2" phase with an expected thickness of 130m. Cuttings and cores will be treated separately as they will be transported, disposed or stored on different ways:

- the cuttings will be disposed, - the cores will moved to laboratory for analyses and kept in storage area afterward.

In both cases, regulation for transportation will apply. The potential activity that could be generated on the Vendsyssel-1 well while drilling and coring the expected 130m thickness of Alum Shales formation is estimated considering a ‘most likely case scenario’, ie. 30% cavings – 80% core recovery. The same exercise was performed for a ‘best case’ and a worst case scenario’, the results of which can be found in Appendices 12.2 to 12.5.

Formation volume – drilling and / or coring the Alum Shales:

Most likely case (30% caving – 80% core recovery)

Total formation drilled out 6.19 m3

100 m of cores in 4" diameter with 80% recovery 0.65 m3

Total volume of cuttings drilled out (Total Formation volume – Cores volume) 5.54 m3

Total volume of cores brought to surface 0.65 m3

Calculations:

The volume calculation is based on the theoretical volume of the hole which is to be drilled.

For the Alum Shales section, the diameter of the hole will be 8-1/2" corresponding to 0.216 m and a volume of 0.037 m3 per drilled meter ((0.216/2)2 x x 1). As the expected thickness of Alum Shales in Vendsyssel-1 is expected to be about 130 m this corresponds to a theoretical volume of 0.037 m3 x 130 m = 4.76 m3 formation drilled out.




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During the crossing of Alum Shales 100 m of cores are expected to be recovered. The volume of those cores should be removed from the total volume of the hole to obtain the volume of cutting to be disposed.

The cores will be 4" diameter corresponding to a volume of 0.008 m3 per meter of core. As it is planned to recover 100 m of cores this correspond to a volume of 0.008 x 100 = 0.81 m3 of cores to be subtracted to the previous total hole volume calculated above to get the cuttings volume: 4.76 – 0.81 = 3.95 m3. As presented in the Appendix 1 as the "Best case".

The above are theoretical calculations for a perfectly calibrated hole and a full recovery of the cores. Two other scenarios have been taken in account: The "worst case": where no core can be recovered (core recovery = 0%, so core volume

= 0 m3) and the instability of the hole is such that an equivalent volume than the one drilled out will fall from the wellbore (100% cavings). In that case the volume of cuttings will correspond to the total volume of the hole (4.76 m3) plus an equivalent volume of formation falling from the wellbore: 4.76 x 2 = 9.52 m3

The "most likely case": corresponding to a "realistic" assessment based on the experience on such operation of the results than can be expected in term of portion of the cores than can be recovered at surface (core recovery = 80% of the 100 m attempted for a volume of 0.65 m3) and falls from the wellbore limited to 30% of additional volume (30% cavings) for a total hole volume of 6.19 m3 (4.76 x 1.3) and a resulting cuttings volume of: 6.19 m3 – 0.65 m3 = 5.54 m3.

All the volumes for those three scenarios are presented in Appendix 1

Formation volume corresponding weights – drilling and / or coring the Alum Shales:

The conversion volume weight is done using the mean density of the Alum Shales as calculated on Terne-1 well (best offset well), i.e. 2.62 g/cm3.

Most likely case (30% caving – 80% core recovery)

Total weight of cuttings drilled out (Total Formation volume – Cores volume) 14.5 t

Total weight of cores bring to surface 1.7 t

7.4 NORM amount evaluation

Quantities of 238U, 232Th and 40K in Alum Shales is evaluated directly in ppm from the XRF analyses on cuttings.

XRF analysis on Terne-1, (considered as the best offset well) shows the following results:

232Th 238U 40K

Max. 19 ppm 81 ppm 65 550 ppm

Min. 9 ppm 5 ppm 23 401 ppm

Mean 12 ppm 36 ppm 32 230 ppm




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8. NORM DEFINITION AND ALERT LEVEL

8.1 NORM definition

NORM results from the natural Uranium 238 and Thorium 232 that is present in the earth’s crust. As these isotopes decay they produce a series of other radioactive isotopes that can be transported to the surface from operations carried out in the oil and gas industry.

Naturally Occurring Radioactive Material (NORM) is considered radioactive when its specific activity exceeds specified threshold values.

The definition of maximum level of activity for normal disposal is based on the one defined in the Danish statutory "Order 192" document.

For a mixture of isotopes a summation rule calculation is used. If giving gives a result of less than or equal to 1, it is not considered radioactive from the point of storage and disposal (Code of Practice for the Safe Handling of NORM from the Oil and Gas Industry, 2003)

Therefore, the following formula applies:

With: k: nuclide Ck: nuclide concentration CU,k: Limit concentration for the nuclide k

The limit for transport / disposal is more constringent than the limit for safety (hazard to people).

The limit for transport / disposal (less or equal to 1) will be used to assess a material as a NORM.

,1




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8.2 Secular equilibrium

For the Alum Shales, deposited more than 400 Million years ago and undisturbed since its deposition, the limit concentration used for each "parent nuclide" is the one for a secular equilibrium which includes the activities of the daughter elements.

238U, 232Th and 40K are therefore considered will the following limits:

238U = 0.5 Bq/g 232Th = 0.5 Bq/g 40K = 20 Bq/g

8.3 NORM alert levels

8.3.1 Activity evaluation

The concentration limits for transport / disposal are expressed in Bq/g;

The elements activity is measured in ppm (from XFR analysis); the activity is converted to concentration in Bq/g using the following:

238U 1 ppm = 0.0122222 Bq/g 232Th 1 ppm = 0.0040741 Bq/g

40K 1 ppm = 0.0000303 Bq/g Applied to the Terne-1 offset well (considered as the most representative to assess the material concentrations for Vendsyssel-1 well) and considering the most likely case scenario, the following activity is calculated:

This activity is calculated for the volume of the "Most likely Case" as describe above (6.19 m3 for cutting and core volume). This volume with a mean density of 2.62 corresponds to 16.2 T.

8.3.2 Amount of maximum Radon-222 release in the air

From the total volume of formation estimated above, it is possible to evaluate the 238U content of the cuttings and cores brought to surface.

As we consider a secular equilibrium the activity of the 222Rn should be equal to the one of the 238U activity (parent element).

Most likely case: 222Rn act = 238U act = 16 210 000 g * 36 * 0.0122222 Bq = 7.13 Mbq

Considering that the 222Rn specific activity is 5.73 x 1015 Bq/g and a density of 9.73 kg/m3, the corresponding mass and volume are:

Most likely case: 7.13 Mbq / 5.73 x 1015 = 1.2440 * 10-9 g = 1.28 x 10-04 ml

The same calculation is performed for the worst case scenario, i.e. - 100% caving / 0% core recovery

232Th 238U 40K Mean concentration 12 ppm 36 ppm 32 230 ppm Weight most likely 16.2T Activity most likely 0.79 MBq 7.13 MBq 15.80 MBq




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- Activity Mean concentration of 84 ppm (taken from offset well Sommerrode-1)

Worst case: 25.6 Mbq / 5.73 x 1015 = 4.4614 * 10-9 g = 4.58x 10-04 ml

These amounts correspond to the total amounts of Radon trapped in the cutting and cores.

Considering a ROP of 1 to 3m/hr for drilling and coring plus the associated tripping duration, this amount will be drilled / cored in 10-15 days.

As a conservative assumption it is therefore considered that the mean Radon daily discharge in the air is 1/10 of the above volumes (if all the Radon is released).

In the worst case scenario, if diluted in a volume of about 258 000 m3 of air it will produce an increase of the activity in the air of only 10 Bq/m3.

This volume corresponds to an hemisphere of 50 m radius around the emission point where the natural activity of the air (10-30 Bq/m3) will be increased by 10 Bq (if there is no dispersion in the air during the day).

Even in the very vicinity of the emission point the increase of the activity linked to the Radon would remain below the normal activity (10-30 Bq/m3)

It should be noticed that in case of total release of the Radon in the air, the secular equilibrium will then be broken and elements of the progeny of the 222Rn (218Po, 214Pb, 214Bi, 214Po, 210Pb, 210Bi, 210Po) in the cuttings reduced compared to the initial state.

Note that there isno existing model for such operation from which the RPP can take reference.

The model created is based on the worst possible scenario to evaluate the maximum possible impact. Hypothesis are:

Worst rock volume Worst Uranium concentration (84 ppm) Total release of trapped Radon Release concentrated in a minimum duration (10 days) Confined volume for dispersion of contamination limited to the site area (50 m radius

hemisphere around emission point = shakers)

Homogenous dilution in the confined volume (despite the Radon density concentrating it at the lowest part of the volume)




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9. MONITORING MEASURES

The risk of personal contamination is deemed to be low during the drilling phase of the operation. Standard compulsory PPE for drilling operations will apply, including, safety glasses, gloves, coverall, safety boots and helmet.

9.1 Measurements on cuttings while drilling

During drilling of VDS001 well, a geochemical unit will be present on location allowing performing X-ray Diffraction (XRD), X-Ray Fluorescence (XRF), Total organic Content (TOC), Pyrolysis analyses on the samples.

Equipments used to measure the XRF data will be:

- BTX-II from Olympus for XRD-XRF (see technical specifications in appendices) - Delta Professional from Olympus for handheld XRF analyses (see technical

specifications in appendices)

From the XRF analyses on cuttings the 238U, 232Th and 40K content of the formation drilled out will be evaluated (in ppm) from samples taken every meter during drilling.

The cuttings will be disposed in cuttings skips. For each skip the first depth and last depth for filling the skip is known.

When drilling the Alum formation, the average concentration of the elements will be calculated per skip, for the cuttings ready to be moved out of the location and disposed.

- Skips volume will be 20 m3 corresponding to 20 x 2.62 = 52.4 T. - The maximum weight for the Alum Shales formation will be, in the worst case, 9.52

m3 x 2.62 = 25 T, which represents half a skip volume - Sample will be measured every 3 m during drilling of the formation. This represents

0.11 m3 of formation and 287 kg of cuttings. During coring as core volume must be subtracted of the previous volume, the sample will represent only 0.086 m3 and 224 kg of cuttings.

- Over the 130 m of Alum Shales formation, it represents about 43 samples to calculate averages.

For each skip, it will therefore be evaluated if the skip remains below the maximum limit for standard disposal - as defined above, in section 8.1 - or if it should be considered as NORM and so declared and treated as such by appliance of the procedures defined in the following paragraphs.

To take in account the accuracy of the measuring equipment, the limit of 1 defined above will lowered to 0.9 to keep a 10% safety margin.

If this limit is reached the specialized company (SEMCO) will be mobilized to assess the value determined from the XRF measurements by a direct measurement on the skip and analyses of samples in laboratory.

- If it is confirmed that the limit of 1 is not reached, the skip will be disposed following the standard procedures.

- If the limit is above 1, the skip content will then be declared and treated as a NORM product by the specialized company.




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9.2 Measurements on cores while drilling

On the cored interval (100 m from 130 m of Alum Shale expected), the activity on cores will be measured with manual handled GR tool.

Those measurements will be used to assess / confirm the validity of the measurements performed on cuttings (coherency of the value, representativeness of the sample analyzed …).

9.3 Measurement on Mud while drilling

If no concentration of the nuclides from the formation can occur, it is still possible that a part of nuclides (most soluble ones) pass from the cuttings to the mud.

The volume of the mud (about 300 m3) compared to the one of the cuttings (about 10 m3 in the worst case) will produce a large dilution of the nuclides and so a very small increase of the activity of the mud.

This will be confirmed by monitoring the activity in the mud with a GR tool located on the active pit () and compared to the base line established on the same mud before drilling the Alum Shales.

During drilling or coring the mud flowing back from the hole is cleaned of the cuttings it contents before being re-injected in the hole. The same mud in circulating during the whole phase of drilling and its composition is just readjusted to keep its parameters as constant as possible. The total volume of mud used (volume in the hole and volume in the surface basins) is about 300 m3.

Before entering in the Alum Shale (from the beginning of the 8-1/2" phase) the GR level of the mud will be measured to establish the "base line". During the drilling/coring of the Alum Shale the GR measured will be measured in real time and the operations stopped as soon the GR value measured reach twice the "base line" value.

In such a case, SEMCO will be mobilized and will be then in charge of evaluating the origin of the contamination of the mud (solid part or fluid part of the mud) with sampling sent for further analysis in the laboratory.

Refer to technical specifications in appendices for the GR measurements

9.4 Environmental monitoring

As part of the planned environmental monitoring campaign, radiochemical analysis shall be carried out on soil, surface water and groundwater and Radon sampling of ambient air.

The environmental monitoring programme will be set up for the three main phases (before, during and after drilling).

The final suite of analysis shall be selected in conjunction with the environmental monitoring consultant carrying out the monitoring activities on behalf of TEP DK.




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10. NORM LEVEL VERIFICATION AND HANDLING

The following comes upon mobilization of the specialized company, in case NORM has been detected, taking into account the 10% safety margin over the activity calculation.

The skip on which potential NORM has been detected will be quarantined and the specialized company call out immediately.

The specialized company contracted is the SEMCO – Bilfinger joint venture.

The RPO can be mobilized on site within a period of 12 hours.

10.1 NORM level verification

NORM verification will be undertaken by the appointed RPO (Radiation Protection Officer) from the contracted specialized company. Only trained personnel should carry out the radiation measurement.

10.1.1 Equipment

Radiation and contamination monitors must be tested by, or under the supervision of a qualified person every 12 months. Test certificates supplied at this time will be retained on file for at least two years from the date of test.

The following monitors should be used based on their ability to detect NORM and that they are intrinsically safe:

Tracerco T201 Contamination Monitor

- The Tracerco T201 is the only intrinsically safe contamination monitor on the market that is suitable for detecting radionuclides found in the oil and gas industry.

- At least 2 operational contamination monitors should be present on site during the NORM verification period. One for operational purposes and one spare.

Tracerco T202 Radiation Monitor

- The Tracerco T202 is one of only a few radiation monitors that are intrinsically safe and has been designed specifically for use in the oil and gas industries.

- It is unlikely that a dose rate monitor is required during the drilling phase of the works. But should be onsite for contingency arrangement purposes.

- At least two operational dose rate monitor should be present on site at all times during the NORM verification period.

Check source

- A 100 Bq Strontium 90 check source should be obtained from Tracerco (equipment manufacturer) for function testing the T201 contamination monitor during the pre-use checks.

- The source must be labeled with a radiation trefoil and kept in a secure location on the site when not in use.

- The RPO will be responsible for ensuring the check source is locked in the secure position within the office.

The equipment calibration and pre-checks will be carried out as per SEMCO guidelines.

- Calibration certificates will be available on site,




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- Instruments will also be calibrated following any repairs.

10.1.2 NORM verification

Monitoring

To determine the extent of contamination, place the T201 monitor probe about 0.5 cm from the potentially contaminated surface on the quarantined cuttings skip. Care should be taken not to contaminate the probe by touching the surface of the item being monitored.

Slowly move the probe across the surface under evaluation at a speed of 1 probe width per second.

Record the maximum reading identified on the monitor in counts per second (cps). This reading is then corrected by subtracting the background.

This operation is to be undertaken a minimum of 3 times per quarantined cuttings skips. The highest measured reading out of the (minimum) 3 measurements is considered.

Same operation is to be performed for dose monitoring with the T202 monitor.

Considering the highest reading with the T201 apparatus,

- If this value is less than two (2) times the background value, then the skip is not considered as NORM.

- If this value is two (2) times or more above the background value, then dedicated analysis on samples are required to enable the disposal.

Sampling

The following minimum samples should be taken in the case the T201 value reads twice above the background value:

- 3 x 50 g samples taken at random from formation above the potentially NORM formation.

- 3 x 50 g samples taken from material within alum shale from the quarantined skip. - 3 x 50 g representative samples taken from the drilling mud.

Samples will be placed in suitable containers and the following information will be recorded:

- Unique Sample Reference. - Date and Time of Collection. - Name of Person Collecting Sample. - Description of contents.

Samples will be marked with a radiation trefoil on the exterior of the sample container.

Samples will be sent to a laboratory that is licensed to, and has the ability to, detect the following isotopes:

- Uranium 238 - Thorium 232

Results must be requested to be expressed in Bq/g.

The licensed laboratory will be able to determine the mass specific activity of U-238 and Th-232, pending formal confirmation from SEMCO

Analysis of aqueous fractions will include the relevant daughter radionuclides (Ra-226, Ra-228, Po-210, Pb-210), pending formal confirmation from SEMCO




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Samples will be sent as Excepted Packages.

Results will be issued within 24 hours. Upon the results of the analysis on the samples, the relevant skip(s) will be declared as NORM for transport and disposal, or not.

10.1.3 Personal protective equipment

The risk of personal contamination is deemed to be low during the drilling phase of the operation. Therefore there are no specific PPE requirements apart from the following:

- Gloves to be worn whilst undertaking contamination monitoring. - Waterproof gloves to be worn whilst sampling potentially radioactive material.

In the event that radioactive material is found during drilling, a risk assessment will be undertaken to determine if additional PPE is required for the task. Usually washable boots and slicker suits will suffice. Although no generation of dust is expected, dust masks can be planned for.

10.2 NORM handling and disposal

The following comes into place if a skip has been declared as NORM.

10.2.1 Handling

Any NORM contaminated item/material must be tagged and stored prior to re-use, transfer or disposal.

All items used within a controlled area, or that have been in contact with contaminated material will be monitored using a T201 by the RPO.

Wrap all contaminated items in thick-gauge polythene sheeting prior to storage although end-capping or placing items directly into a sealable container may be appropriate alternatives.

Each item should be tagged with the appropriate information, and a record of each item should be made and retained on the record form.

Items that are to be stored should be placed in a storage area. The storage area should be clearly demarcated to prevent access to unauthorized persons.

10.2.2 Segregation

Cuttings and cores that are found to be contaminated must be segregated and put into drums or containers that are certified for transporting material as LSA-I containers.

Each container should be tagged with the appropriate information, and a record of each item should be made and retained on the record form.

Containers that are to be stored should be placed in a storage area. The storage area should be clearly demarcated to prevent access to unauthorized persons.

10.2.3 Storage

Any accumulated NORM must be kept secure and ideally in a locked store kept solely for radioactive materials. A sign must be displayed external to the store or storage area (preferably on the door or lid) to warn persons in the vicinity that the store may contain radioactive materials. The sign must include a trefoil and the word ‘Radioactive’. In the case




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of drums of NORM, a secure area may be appropriate. Furthermore the warning sign for ionizing radiation must be in accordance with Danish Standard: DS 734.1 and 734.2

Dose rate on the surface of the store should not exceed 2.5 µSv/h. If the dose rate exceeds 2.5 µSv/h, consideration shall be given to the designation of the area as a controlled area.

The store shall be situated away from accommodation and office areas; i radioactive materials store shall not be situated near explosives store or flammable materials.

The storage site itself must be fenced and the dose rates at the fence must not exceed 7.5 µSv/h.

Waste containers must be sheltered against rain/snow and protected against corrosion. Metallic containers must not be used

10.2.4 Transport

If material or waste needs to be taken off of the worksite, then this will be transported under the European Agreement Concerning the International Carriage of Dangerous Goods by Road, unless it can be shown to be exempt from the regulations.

A qualified Dangerous Goods Safety Adviser (DGSA) will be appointed to advise the company on how to package, label and complete paperwork for packages that contain radioactive material.

The DGSA will have had specific training in the use of the European Agreement Concerning the International Carriage of Dangerous Goods by Road (Known as the ADR code).

The appointed DGSA is responsible for supplying suitable consignment notes, training, auditing transport arrangements and compiling an annual report on transport for the site.

The Site RSES is responsible for ensuring that the DGSA is consulted and that any driver has the appropriate licenses and training.

10.2.5 Disposal

The contaminated material will be disposed at Riso (Danish decommissioning centre).

Copies of the permissions or licenses must be provided before any radioactive material is permitted to leave the site




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11. REPORTING

11.1 Internal reporting

Geochemical analysis will be reported to the RSES by the Total Well Site Geologist. Results of the geochemical analysis on the cuttings will be reported on a daily basis.

If mobilized, SEMCO-Bilfinger will issue a daily report to Total E&P Denmark.

11.2 External reporting

All radionuclide data measured on cores, cuttings, mud, fluids or gasses generated from the Vendsyssel-1 exploration drilling well will be reported directly to NIRP.

A report will be issued to the NIRP at the termination of the exploration phase at the latest, or whenever TOTAL’s activities at the Vendsyssel-1 for other reasons are temporarily or permanently ceased, detailing all the relevant results from radiation measurements taken during the operations on the well and a statement of the total quantity of NORM that had been handled over the period.




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12. APPENDICES

12.1 Appendix 1: RPOs




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12.2 Appendix 1: VDS001 – amount of formation involved

Three cases are considered to assess the potential activity that could be generated on VDS001 well drilling coring the expected 130m thickness of Alum Shales formation:

- best case (no caving; 100% core recovery limiting the Alum Shale formation recovered)

- most likely case (30% cavings – 80% core recovery) - worst case scenario (100% cavings – 0% core recovery)

Formation volume – drilling and / or coring the Alum Shales:

Best case (no caving – 100% core recovery) Total formation drilled out (130 m in 8-1/2" diameter – 0% caving) 4.76 m3

100 m of cores in 4" diameter with 100% recovery 0.81 m3 Total volume of cuttings drilled out (Total Formation volume – Cores volume) 3.95 m3 Total volume of cores brought to surface 0.81 m3

Worst case (100% caving – 0% core recovery) Total formation drilled out 9.52 m3


Most likely case (30% caving – 80% core recovery) Total formation drilled out 6.19 m3


Formation volume corresponding weights – drilling and / or coring the Alum Shales:

The conversion volume weight is done using the mean density of the Alum Shales as calculated on Terne-1 well (best offset well), i.e. 2.62 g/cm3.

Best case (no caving – 100% core recovery) Total weight of cuttings drilled out (Total Formation volume – Cores volume) 10.3 t Total weight of cores bring to surface 2.12 t

Worst case (100% caving – 0% core recovery) Total weight of cuttings drilled out (Total Formation volume – Cores volume) 24.9 t Total weight of cores bring to surface 0.00 t

Most likely case (30% caving – 80% core recovery) Total weight of cuttings drilled out (Total Formation volume – Cores volume) 14.5 t Total weight of cores bring to surface 1.7 t




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12.3 Appendix 1: Offset wells XRF analysis results

XRF analysis performed on the offset wells for the Alum Shales shows the following results.

Terne-1 Albjära-1 Sommerodde-1 232Th 238U 40K 232Th 238U 40K 232Th 238U 40K

Max. 19 ppm 81 ppm 65 550 ppm 43 ppm 293 ppm 46 171 ppm 25 ppm 235 ppm 45 721 ppm Min. 9 ppm 5 ppm 23 401 ppm 0 ppm 0 ppm 74 28 ppm 10 ppm 28 ppm 14 634 ppm

Mean 12 ppm 36 ppm 32 230 ppm 16 ppm 75 ppm 28 301 ppm 16 ppm 84 ppm 25 612 ppm




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12.4 Secular equilibrium

For the Alum Shales, deposited more than 400 My ago and undisturbed since its deposit, the limit concentration used for each "parent nuclide" is the one for a secular equilibrium which includes the activities of the daughter elements. 238U, 232Th and 40K are considered will the following limits:

238U = 0.5 Bq/g 232Th = 0.5 Bq/g 40K = 20 Bq/g

Figure 1: Decay chain for Uranium series Figure 2: Decay chain for Thorium series

238U-sec 234Th, 234Pa-m, 234Pa, 234U, 230Th, 226Ra, 222Rn, 218Po, 214Pb, 214Bi, 214Po, 210Pb, 210Bi, 210Po

232Th-sec 228Ra, 228Ac, 228Th, 224Ra, 220Rn, 216Po, 212Pb, 212Bi, 212Po, 208Tl




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12.5 NORM alert levels

12.5.1 Activity evaluation

The concentration limits for transport / disposal are expressed in Bq/g; knowing the elements activity in ppm (from XFR analysis) the activity is converted to concentration in Bq/g using the following:

238U 1 ppm = 0.0122222 Bq/g 232Th 1 ppm = 0.0040741 Bq/g

40K 1 ppm = 0.0000303 Bq/g

Applied to the three offset wells considered, it gives the following activity (in Bq):

Terne-1 Albjära-1 Sommerodde-1 232Th 238U 40K 232Th 238U 40K 232Th 238U 40K

Mean concentration 12 ppm 36 ppm 32 230 ppm 16 ppm 75 ppm 28 301 ppm 16 ppm 84 ppm 25 612 ppm Weight most likely 16.2 t Weight best case 12.42 t

Weight worst case 24.9 t Activity most likely 0.79 MBq 7.13 MBq 15.80 MBq 1.06 MBq 14.85 MBq 13.87 MBq 1.06 MBq 16.63 MBq 12.56 MBq Activity best case 0.61 MBq 5.46 MBq 12.11 MBq 0.81 MBq 11.39 MBq 10.64 MBq 0.81 MBq 12.75 MBq 9.63 MBq

Activity worst case 1.22 MBq 10.96 MBq 24.28 MBq 1.62 MBq 22.83 MBq 21.32 MBq 1.62 MBq 25.56 MBq 19.30 MBq

Terne-1 is considered as the most representative to assess the material concentrations for Vendsyssel-1 well.

Amount of maximum Radon-222 release in the air

From the total volume of formation estimated above, it is possible to evaluate the 238U content of the cuttings and cores brought to surface.

As we consider a secular equilibrium the activity of the 222Rn should be equal to the one of the 238U activity (parent element).

Best case: 222Rn act = 238U act = 12 500 000 g * 36 * 0.0122222 Bq = 5.46 Mbq Worst case: 222Rn act = 238U act = 24 938 470 g * 84 * 0.0122222 Bq = 25.6 Mbq

Most likely case: 222Rn act = 238U act = 16 210 000 g * 36 * 0.0122222 Bq = 7.13 Mbq

Considering that the 222Rn specific activity is 5.73 x 1015 Bq/g and a density of 9.73 kg/m3, the corresponding mass and volume are:

Best case: 5.46 Mbq / 5.73 x 1015 = 0.95371 * 10-9 g = 0.980 x 10-04 ml Worst case: 25.6 Mbq / 5.73 x 1015 = 4.4614 * 10-9 g = 4.58x 10-04 ml

Most likely case: 7.13 Mbq / 5.73 x 1015 = 1.2440 * 10-9 g = 1.28 x 10-04 ml

These amounts correspond to the total amounts of Radon trapped in the cutting and cores.




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Considering a ROP of 1 to 3m/hr for drilling and coring plus the associated tripping duration, this amount will be drilled / cored in 10-15 days.

As a conservative assumption it is therefore considered that the mean Radon daily discharge in the air is 1/10 of the above volumes (if all the Radon is released).

In the worst case scenario, if diluted in a volume of about 258 000 m3 of air it will produce an increase of the activity in the air of only 10 Bq/m3.

This volume corresponds to an hemisphere of 50 m radius around the emission point where the natural activity of the air (10-30 Bq/m3) will be increased by 10 Bq (if there is no dispersion in the air during the day).

It should be noticed that in case of total release of the Radon in the air, the secular equilibrium will then be broken and elements of the progeny of the 222Rn (218Po, 214Pb, 214Bi, 214Po, 210Pb, 210Bi, 210Po) in the cuttings reduced compared to the initial state




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12.6 Monitoring equipment specifications

Olympus BTX-II




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Olympus Delta Professional




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GEOLOG Gamma Ray Surveyor




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T201 Specification

T202 Specification

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