NORM Primer: Industry Edition

EERCEnergy & Environmental Research Center®

Putting Research into Practice

(naturally occurring radioactive materials)R E S P O N S I B L E • S A F E • S E C U R E • G R O W T H

SM

NORM

NORM PrimerINDUSTRY EDITION

This primer is intended to provide the reader with a brief, readable summary of the breadth of radiation science behind NORM (naturally occurring radioactive materials) regulations. Because radiation is one of the most complex topics in physics and because biological damage due to radiation is an inexact science, it is impossible to reduce the volume of knowledge in radiation physics to a single booklet. Therefore, this booklet is meant to provide the reader with enough information to begin asking good questions. The opinions provided at the end of this book are meant to foster conversation regarding prudent, logical, and beneficial oilfield NORM regulatory language formulation. The codification of wise NORM regulations will require active participation from oil and gas industry leaders, state regulatory bodies, radiation physicists, and field survey equipment manufacturers. It is hoped that this booklet will serve as a start to that discussion.

This industry edition is one of three editions, each geared for different audiences, but all containing the same factual, scientifically required basis. This industry edition is intended as a tool for producers and service providers to help them digest this complex topic in a quick overview format. It provides the fundamental science required to make wise decisions regarding strategies on NORM waste management and NORM waste disposal.

Jay C. AlmlieSenior Research ManagerEnergy & Environmental Research Center

NORM Primer 1

What Is NORM? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Radiation Fundamentals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Handling and Disposal of NORM Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Regulation of NORM Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Conclusions and Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Table of Contents

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NORM Primer 3

WHAT IS NORM?

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NORM Defined Naturally Occurring Radioactive Materials (NORM)Naturally occurring radionuclides are present at varying concentrations in Earth’s crust and can be concentrated and enhanced by processes associated with the recovery of oil and gas.

Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM)TENORM is created when industrial activity increases the concentrations of radioactive materials or when the material is redistributed as a result of human intervention.

North Dakota producers distinguish between true TENORM waste and the majority of waste generated by oil production activities.

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Potential Sources of NORM Related to Oil ProductionSome of the most common potential sources of NORM waste related to oil production activities are shown below.

Pipe ScaleTank Sludge

Drilling Mud

Produced Water

Drill Cuttings

Used Water Filtration

Socks

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Potential Sources of NORM Source Radionuclides Characteristics Occurrence

Radium in Scales 226Ra, 228Ra, 224Ra, progeny Hard deposits of Ca, Sr,Ba sulfates andcarbonates

Wet parts of productioninstallations

Well completions

Radium in Sludge 226Ra, 228Ra, 224Ra, progeny Sand, clay, paraffins,heavy metals

Separators, skimmer tanks

Lead in Deposits 210Pb, progeny Stable lead deposits Wet parts of gas productioninstallations

Well completions

Lead in Films 210Pb, progeny Very thin films Oil and gas treatment andtransport

Polonium in Films 210Po Very thin films Condensate treatment facilities

Polonium in Condensates

210Po Gas production

Natural Gas 222Rn210Pb, 210Po

Noble gas

Plated on surfaces

Consumers domain

Gas treatment systems

Produced Water 226Ra, 228Ra, 224Ra, 210Pb Large volumes in oil production

Each production facility

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RADIATION FUNDAMENTALS

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Radiation Emitted by NORM

++

Helium Nucleus (2+ charge)

Gamma Photon

Electron (- charge)

Three types of radiation are emitted by NORM:

• Alpha (α)

– Helium nuclei that are heavy and have a double positive charge, which causes them

to lose their energy very quickly in matter

– Stopped by a sheet of paper or the surface layer of your skin

– Considered hazardous to a person’s health only if inhaled or ingested

• Beta (β)

– Electron, one negative charge – Much smaller, interacts more slowly with material – Stopped by thin layers of metal or plastic – Considered hazardous only if ingested or inhaled

• Gamma ()

– Associated with alpha and beta decay and is a form of high-energy electromagnetic radiation that interacts lightly with matter

– Shielded by thick layers of lead or other dense materials

– Considered an external hazard to living tissue

–

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Shielding for Radiation Types

Paper Plastic Steel Lead

Although radiation is ubiquitous in our environment, it is desirable to keep radiation exposure as low as reasonably achievable (ALARA). This is accomplished by the techniques of time, distance, and shielding.

• Time: The less time spent in a radiation field, the less radiation exposure is received by the exposed body.

• Distance: The farther a person is from a source of radiation, the lower the radiation dose. Levels decrease by a factor of the square of the distance. Think of it as sound. The farther you are from a jet engine, the less your ears hurt.

• Shielding: Placing a radioactive source behind a barrier material can reduce radiation exposure.

Tissue

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Radiation UnitsThe four different but interrelated categories of radiation measurement are radioactivity, exposure, absorbed dose, and dose equivalent (READ).

• RADIOACTIVITY is the amount of ionizing radiation (, , and x-rays or neutrons) released by a material and represents how many atoms in the material decay in a given time period.

• EXPOSURE is the amount of radiation traveling through the air. Most radiation monitors used in the oil fields measure exposure.

• ABSORBED DOSE describes the amount of energy that radioactive sources deposit in materials through which they pass.

• DOSE EQUIVALENT (or effective dose) combines the amount of radiation absorbed and the medical effects of that type of radiation. For beta and gamma radiation, the dose equivalent is the same as the absorbed dose. By contrast, the dose equivalent is larger than the absorbed dose for alpha and neutron radiation, because these types of radiation are more damaging to the human body.

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Specific Activity = Radioactivity per Unit Mass

Radioactivity Transmitted Through Air

Radioactivity Received by Another Body

Units Get Confusing• For many practical health physics problems, over

the range of energies usually encountered, the rad (dose) and Roentgen (exposure) units are often used interchangeably:

– One g of air will absorb 87 ergs of energy, and 1 g of soft tissue will absorb 96 ergs of energy when exposed to a radiation field to produce an exposure of 1 Roentgen.

• The Roentgen is a special unit, in part, because it is used only with radiation.

• Generally, radioactivity units (pCi) are not convertible to dose units (rad, rem, Sv), or vice versa.

For practical purposes, 1 R (exposure) = 1 rad (absorbed dose) = 1 rem or 1000 mrem (dose equivalent).

No equivalency can be made between radioactivity and exposure or dose because energy levels, shielding, and distance all play roles in how much radioactivity is transmitted through air to deposit in materials.

Radioactivity• Becquerel, Bq (SI)• Curie, Ci (imperial)

Exposure• Roentgen (R, for radiation, only)

Dose• Dose absorbed – Gray, Gy (SI) – Rad, rad (imperial)

• Dose equivalent – Sievert, Sv (SI) – rem, r (imperial)

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Typical Field Instrumentation • These instruments count disintegrations per minute,

received through an air medium, and typically count either -/-producing disintegrations or -producing disintegrations.

• These instruments measure exposure in µSv/hr or µR/hr.

• These instruments are not capable of:

– Identifying isotopes.

– Correlating between measured disintegrations per minute and the regulation-driven radioactivity per unit mass in specific isotope energy ranges.

– Determining true radioactivity, measured directly.

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Analytical Aspects of NORM WasteOnly under certain conditions can reliable estimates of the activity concentration of -emitting nuclides be obtained from the readings of dose rate on the outside of a waste container.

Usually, the radiological characterization of NORM waste will demand nuclide-specific analysis by high-resolution gamma spectrometry at a qualified laboratory. The method requires sophisticated equipment operated by experienced analysts.

As the shielding provided by the scale or sludge mass itself and the wall of the equipment can be substantial, it is usually not possible to reliably convert the measured dose rates into activity per unit mass of scale or sludge.

Source: IAEA Radiation Protection and the Management of Radioactive Waste in the Oil & Gas Industry, Vienna, 2010, Training Course Series No. 40.

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Food Source 40K pCi/g 226Ra pCi/g

Banana 3.52 Negligible

Brazil Nut 5.60 1–7

Carrot 3.40 0–0.002

White Potato 3.40 0–0.0025

Beer 0.39 Negligible

Red Meat 3.00 Negligible

Lima Bean 4.64 0–0.005

Drinking Water – Negligible

Common Radiation FactoidsTypical Radioactivity Levels• Average coal – 4 pCi/g

• Cat litter – 5 pCi/g

• Coffee grounds – 27 pCi/g

• Granite countertop – 27 pCi/g

• Coal ash – 54 pCi/g

• Phosphate fertilizer – 123 pCi/g

• Uranium ore (0.3%) – 13,500 pCi/g

• Food: see table below

Radioactivity is all around us. Many everyday items are radioactive. Would you think twice about touching freshly ground coffee or even carrying a packet around in your pocket? Probably not, yet the average packet of ground coffee likely is more radioactive than much of the oilfield waste currently classified as NORM waste and trucked to licensed disposal facilities.

Dosage Limits• OSHA (Occupational Safety and Health Administration)-defined minor – 0.5 rem (yearly)

• OSHA-defined worker – 5 rem (yearly)

• Astronauts – 25 rem (lifetime)

• Nausea ≈ 50 rem (acute)

• 100% fatality ≈ 200 rem/hr (acute)

Typical Doses• Average national background – 620 mrem (yearly) – Half of this is from radon gas.

• Living next to nuclear plant for 1 yr – 1 mrem

• Sleeping next to person for 1 yr – 2 mrem

• 6-hr airplane flight at altitude – 4 mrem

• 0.5-sec mammogram – 40 mrem

• Barium x-ray – 400 mrem

• 1 pack of cigarettes/day for 1 yr – 1300 mrem

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EPA Claims of Radioactivity Ranges for NORM WastesVague information such as this offered on the U.S. Environmental Protection Agency (EPA) Web page may provide impetus for industry to develop a better inventory data set.

The public will focus on the "high" numbers, which may or may not be representative of Bakken numbers. Industry's challenge is to develop better data to represent the correct status.

Radiation Level, pCi/g

Low Average High

Phosphate Fertilizer 0.5 5.7 21

Soils of the United States 0.2 – 4.2

Oil and Gas Production Wastes

Produced water, pCi/L 0.1 – 9000

Pipe/tank scale <0.25 <200 >100,000

Drinking Water Treatment Wastes

Treatment sludge, pCi/L 1.3 11 11,686

Treatment plant filters – 40,000 –

Wastewater Treatment Wastes

Treatment sludge, pCi/L 0 2 47

Treatment plant ash 0 2 22

Coal AshBottom ash 1.6 3.5–4.6 7.7

Fly ash 2 5.8 9.7

Uranium Mining Wastes

Uranium mining overburden – – Low

Uranium in situ leachate evaporation pond 3 30 3000

Solids 300 – 3000

U.S. EPA, www.epa.gov/radiation/tenorm/index.html (accessed 2014).

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It All Starts with Chemistry!

When we discuss NORM, we focus on a few elements ….

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When we discuss NORM, we focus on a few elements ….

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U

Th Th

Ra

Rn

Po

Pb

Tl

Hg

Tl

Pb Pb

Bi Bi

Po Po

At

U

Pa

23892

23492

23491

23492

22688

22286

21483

21083

21884

21482

21082

21081

20682

20681

20680

21484

21084

21885

23090

27 days

1602 years

3.8 days

3.1 minutes

20 minutes

1.3 minutes 4.2 minutes

8.1 minutes

26.8minutes

5 days

138 days

22.3 years Stable

1.5 seconds

0.1643 seconds

27 days

245,500 years

75,380 years

4.5e9years

–

–

–

–

–

–

–

–

Uranium

Protactinium

Thorium

Actinium

Radium

Francium

Radon

Astatine

Polonium

Bismuth

Lead

Thallium

Mercury

Decay of 238U Results in NORM

Actinides

Alkaline-Earth Metals

Halogens

Metalloids

Noble Gases

Poor Metals

Transition Metals

An important decay chain is the decay of 238U• 222Rn is radioactive and has several characteristics that magnify its health effects:

– Radon is a gas. It can seep through soil and cracks in rock into the air and accumulate to high concentrations.

– Radon decay emits particles, radiation that presents the greatest hazard to lung tissue.

– Radon’s very short half-life (3.8 days) means that it emits alpha particles at a high rate.

• 226Ra, 210Po, and 210Pb are other products of this decay chain that are monitored in NORM wastes

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Thorium

Actinium

Radium

Francium

Radon

Astatine

Polonium

Bismuth

Lead

Thallium

Th Th

RaRa

Rn

Pb

Tl

Bi

Pb

Po Po

Ac22889

23290

22892

22086

22488

22888

21684

21284

20881

21282

21484

21283

1.41e+10years

1.9 years

55 seconds

3.6 days5.7 years

0.14seconds

3e-07seconds

10.6 hours

3.1 minutes

Stable

61 minutes

6.1 minutes

–

–

–

–

Decay of 232Th Results in NORM

Actinides

Alkaline-Earth Metals

Halogens

Metalloids

Noble Gases

Poor Metals

Transition Metals

–

• A different radioactive decay process results in 228Ra, another isotope monitored in NORM wastes.

• Like 226Ra, 228Ra is also radioactive and has several characteristics that magnify its health effects:

– Radium, like calcium, will be carried to bones.

– Because 228Ra is a emitter, the radium isotope will continue to bombard surrounding tissue with radiation until it is eventually flushed out of the body, increasing the chances of cancer.

– Bone cancer, anemia, and cataracts are some of the documented medical issues associated with 228Ra.

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HANDLING AND DISPOSAL OF

NORM WASTES

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NORM Disposal OptionsDisposal Method

Land Spreading

Land Spreading with Dilution (land farming)

Nonretrieved Line (surface) Pipe

Burial with Unrestricted Site Use

Commercial Oil Industry Waste Facility

Commercial NORM Waste Facility

Commercial Low-Level Radioactive Waste Facility

Plugged and Abandoned Well

Well Injection Hydraulic Fracturing

Equipment Release to Smelter

Description

Land spreading involves disposal by spreading sludge and scale on the surface/open lands in an area where NORM was not originally present above background levels.

Land spreading with dilution involves mixing of the applied NORM thoroughly within the top 8-inch (20.3-cm) layer of soil using agricultural equipment in an area where NORM was not originally present above background levels.

Buried line pipe used at a facility could be abandoned in place after being flushed to remove any oil or gas present.

Burial with unrestricted site use involves burial of NORM with at least 15 feet (4.6 m) of cover that is level with the surrounding terrain, minimizing erosion potential.

Disposal in a commercial oil industry waste facility assumes burial with other oilfield wastes where NORM represents less than 7% of the total waste volume.

A NORM waste disposal site is designed to contain NORM for long periods, and its control may revert to a national authority for permanent monitoring and restricted future use after closure.

A low-level radioactive waste disposal facility is defined and licensed under national regulations with numerous protective features and restrictions.

Well abandonment operations provide an opportunity to dispose of NORM.

Sludge and scale wastes could be injected or fractured into formations that are isolated geologically and mechanically.

Smelting may be a viable option for NORM-contaminated tubulars and other equipment.

Currently favored and widely accepted options.

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Licensed NORM Disposal Sites in the United States

AlabamaArizona Arkansas

CaliforniaColorado

Connecticut

Delaware

Florida

Georgia

Idaho

Illinois

Wyoming

Wisconsin

West Virginia

Washington

Virginia

Vermont

Utah

Texas

Tennessee

South Dakota

South Carolina

Rhode Island

Pennsylvania

Oregon

Oklahoma

Ohio

North Dakota

North Carolina

New York

New Mexico

New Jersey

New Hampshire

Nebraska

Montana

Missouri

Mississippi

Minnesota

Michigan

Massachusetts

Maryland

Maine

Louisiana

KentuckyKansas

Iowa

IndianaNevada Clean Harbors

Clean Harbors

U.S. Ecology

U.S. Ecology

U.S. Ecology

Lotus, LLCChemical Waste Management

Wayne Disposal, Inc.

Oaks Disposal Services

M.B. Environmental Service

UNITED STATES

NORM Disposal Sites

NORM Disposal Facilities (landfills)

Injection Wells

NORM Decontamination Facilities

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REGULATION OF NORM WASTES

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States Have Primacy over NORM Disposal RegulationsWastes containing NORM are generally not regulated by federal agencies:

• One exception is that the transportation of NORM-containing wastes is subject to U.S. Department of Transportation regulations.

• NORM management activities may be subject to regulations promulgated by OSHA.

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Summary of State NORM Regulations• In 1997, the Conference of Radiation Control Program

Directors (CRCPD), a group of state and local regulators, developed a set of suggested state regulations for control of radiation (SSRCR) as a model standard guidance for regulating NORM in an attempt to lead the states to uniform regulation of NORM.

• This document is commonly referred to as “the CRCPD Part N Template” and attempts to answer the following questions:

– Do I have TENORM?

– How do I dispose of TENORM waste?

– What radiation measurements are required to comply with Part N?

• Most states that regulate NORM do so on the basis of a threshold radioactivity level (emission) – pCi/g of 226Ra and 228Ra above background

• Many of these states use the 5-pCi/g threshold recommended by Part N (see Section 7, ¶ b.ii.)

• No specific measurement methodology is prescribed within Part N (see Section 6):

– The Energy & Environmental Research Center (EERC) has discussed measurement methodology with many radiation instrument manufacturers. None had field-based instruments that could measure pCi/g of specific Ra isotopes.

Weakness of Part N – Field Employability• The activity thresholds suggested in Part N are largely

derived from modeling done at Argonne National Laboratory that attempted to correlate an activity level that results in predicted absorbed dose levels and associated potential biological damage.

• Many broad assumptions need to be made to make these correlations.

• Measurement of total radioactivity of specific isotopes (and associated energy levels) is complex, requiring time, advanced analytical equipment, and detailed laboratory methodologies.

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15 States with NORM-Specific Regulations

The numbers in each state are grossly indicative of that state’s threshold (in pCi/gr 226Ra and/or 228Ra) for exemption from state NORM disposal rules. This is an extreme simplification. Refer to state-specific regulations for more accurate detail.

WA

MT ND

SDWY

ID

UT

NV

OR

CA

AZ

NM

AK

HI

CO

NE

KS

OK

TX

AR

MO

IA

MN WI

IL IN

KY

TN

ALMS

LA

GA

FL

SC

NC

VAwv

OH

PA

NY

VTNH

ME

MA

CT RI

DENJ

MD

NORM-Specific Regulation States

WY, KY, and PA regulate the presence of radium in produced water that is discharged into surface water.

MI

5

55

5553030

5

5

5

5

50

270

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15 States with NORM-Specific Regulations

Alabama RegulationsAlthough Alabama does not have NORM-specific regulations, it does define thresholds that require a radioactive license on its Department of Public Health Web site (www.adph.org/radiation/Default.asp?id=1907).

To determine if the NORM concentration is such that it will require a radioactive material license, Alabama has adopted two thresholds:

• >50 µR/hr (background included) at contact with item. This threshold is only to be used for discreet items such as pipes or tanks and the TENORM-contaminated scale or sludge contained in these pipes or tanks.

• >5 pCi/g of combined 226Ra and 228Ra.

Arkansas RegulationsIn accordance with Arkansas State Board of Health Rules and Regulations for Control of Sources of Ionizing Radiation, RH-1210g, exceptions to regulated disposal are provided as follows:

226Ra or 228Ra in soil averaged over any 100 m² shall not exceed the background level by more than:

a) 5 pCi/g, averaged over the first 15 cm of soil below the surface.

b) 15 pCi/g, averaged over 15-cm-thick layers of soil more than 15 cm below the surface.

Georgia RegulationsIn accordance with Georgia Rule 391-3-17-.08, exceptions to regulated disposal are provided as follows:

1 (i) 30 pCi/g of 226Ra or 228Ra in soil, averaged over any 100 m² and averaged over the first 15 cm of soil below the surface, if Rn emanation rate is <20 pCi/m²/s.

(ii) 30 pCi/g of 226Ra or 228Ra in media other than soil, if Rn emanation rate is <20 pCi/m²/s.

2 (i) 5 pCi/g of 226Ra or 228Ra in soil, averaged over any 100 m² and averaged over the first 15 cm of soil below the surface, if Rn emanation rate is >20 pCi/m²/s.

(ii) 5 pCi/g of of 226Ra or 228Ra in media other than soil, if Rn emanation rate is >20 pCi/m²/s.

3 (i) 150 pCi/g of any other NORM radionuclide in soil, averaged over any 100 m² and averaged over the first 15 cm of soil below the surface, if these concentrations are not exceeded at any time.(ii) 150 pCi/g of any other NORM radionuclide in media other than soil, if these concentrations are not exceeded at any time.

Kentucky RegulationsIn accordance with Kentucky Administration Regulations Title 401, Chapter 10:031, the Division of Oil and Gas does not have specific NORM regulations; however, the Department for Environmental Protection, Division of Water, regulates the presence of radium in produced water that is discharged into surface water (<5 pCi/L).

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Louisiana RegulationsIn accordance with Louisiana Administrative Code Title 33, Part XV, Chapter 14, §1404 and §1412, exceptions to regulated disposal are provided as follows:

NORM waste:• <5 pCi/g of 226Ra or 228Ra, above background.

• <150 pCi/g of any other radionuclide.

Contaminated equipment:• Exposure level <50 mR/hr at any accessible point.

Land:• <5 pCi/g of 226Ra or 228Ra above background, averaged over the first 15 cm.

• <15 pCi/g above background over everything deeper.

• <30 pCi/g of 226Ra or 228Ra, averaged over 15-cm depths, provided the total effective dose equivalent does not exceed 0.1 rem (1 mSv) in a year.

Maine RegulationsIn accordance with Maine Department of Health and Human Services Rule 10-144, Chapter 220, Part N, exceptions to regulated disposal are provided as follows:

• <5 pCi/g of 226Ra and 228Ra, excluding natural background.

• Distribution and disposal of fertilizers are exempt from these requirements.

• Other TENORM is exempt when the agency makes a determination that a maximally exposed individual will not receive a dose of >0.1 rem in 1 year from all exposure pathways.

Michigan RegulationsIn accordance with the Michigan Department of Environmental Quality’s Ionizing Radiation Rules 123(3)e, 237(1), 237(2), 237(3), 253, and 272, exceptions to regulated disposal are provided as follows:

• Materials containing 226Ra <50 pCi/g, averaged over any single shipment.

• Any NORM wastes containing 226Ra at any concentration generated during plugging and abandonment operations, disposed of downhole.

Minnesota RegulationsIn accordance with Minnesota Administrative Rules (MAR) Chapter 4731, exceptions to regulated disposal are provided as follows:

• Material activity concentrations and consignment activity levels <270 pCi/g for both 226Ra and 228Ra (MAR Chapter 4731.0422, Subpart 3).

• Material activity concentrations consignment activity levels for other radionuclide mixtures, broken down by radiation emission types (α, β, ) <270 pCi/g (MAR Chapter 4731.0423, Subpart 6).

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Mississippi RegulationsIn accordance with Title 15, Part 21, Subpart 78, Chapter 1, Subchapter 11, Rule 1.11.4 of Mississippi regulations, exceptions to regulated disposal are provided as follows:

• <5 pCi/g of 226Ra or 228Ra above background.

• <30 pCi/g of 226Ra or 228Ra, averaged over any 100 m², if the radon emanation rate <20 pCi/m²/s.

• <150 pCi/g of any other radionuclide, if these concentrations are not exceeded at any time.

• Equipment <25 mR/hr above background radiation at any accessible point.

Exempt products or materials:

1. Phosphate and potash fertilizer2. Phosphogypsum for agricultural uses

Produced waters from crude oil and natural gas production are exempt from the requirements of these regulations if the produced waters are reinjected in an approved well.

New Jersey RegulationsIn accordance with New Jersey Administrative Code Title 7, Chapter 28, Subchapter 4.3(a)5, exceptions to regulated disposal are provided as follows:

• <5 pCi/g of 226Ra and 228Ra above background.

New Mexico RegulationsIn accordance with New Mexico Administrative Code Title 20, Chapter 3, Part 1, Subpart 14, exceptions to regulated disposal are provided as follows:

In soils, in 15-cm layers averaged over 100 m²:

• <30 pCi/g of 226Ra above background.

• <150 pCi/g of any other NORM radionuclide above background.

Exempt products/materials:

• Natural gas and natural gas products as fuels.

• Crude oil and crude oil products as fuels .

• Removable scale from gas processing and dry gas distribution is exempt if <150 pCi/g of 210Pb in scale.

• Produced water is exempt if reinjected into a permitted well or stored in a permitted impoundment.

Other exemptions:

• Exposure readings <50 mR/hr, including background radiation levels, at any accessible point.

Surface contamination exemptions:

• <10 dpm/cm² (disintegrations per minute per square centimeter).

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Ohio RegulationsIn accordance with Ohio Administrative Code Chapter 3701-39, §02.1, exceptions to regulated disposal are provided as follows:

Soil or nonsoil media containing 226Ra or 228Ra with Rn emanation rate of <20 pCi/m²/s

• <27 pCi/g , if the concentration of 226Ra or 228Ra, averaged over any 100 m² and averaged over the first 15 cm below the surface.

Soil or nonsoil media containing 226Ra or 228Ra with Rn emanation rate of >20 pCi/m²/s

• <5 pCi/g , if the concentration of 226Ra or 228Ra, averaged over any 100 m² and averaged over the first 15 cm below the surface.

Soil or nonsoil media containing other radionuclides

• <135 pCi/g , if the concentration of radionuclides, averaged over any 100 m² and averaged over the first 15 cm below the surface.

Materials or equipment contaminated with scale or residue

• Exposure level <25 mR/hr above background at any accessible point

Oregon RegulationsIn accordance with Oregon Administrative Rule 333-117-0040, exceptions to regulated disposal are provided as follows:

• <5 pCi/g of Ra.

• <150 pCi/g of any other radionuclide, if these concentrations are not exceeded at any time.

Exempt products:

• Brazil nuts

• Phosphate and potash fertilizer

• Phosphogypsum for agricultural uses

• Natural gas and natural gas products as a fuel

Pennsylvania RegulationsIn accordance with Pennsylvania Code Title 25, Chapter 95, 40 Pa.B.4835, the Bureau of Oil and Gas does not have specific NORM regulations; however, the Department for Environmental Quality regulates the amount of radium produced by oil and gas operations and discharged into surface water.

South Carolina RegulationsIn accordance with South Carolina Code of Regulations 61-63, Title A, Part IX, exceptions to regulated disposal are provided as follows:

Activity Concentration

• <30 pCi/g of 226Ra or 228Ra in soil or nonsoil media, averaged over any 100 m² and averaged over the first 15 cm below the surface, provided the radon emanation rate is <20 pCi/m²/s.

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South Carolina Regulations (continued)• <5 pCi/g of 226Ra or 228Ra in soil or nonsoil media, averaged over any 100 m² and averaged over the first 15 cm below the surface, if the radon emanation rate is >20 pCi/m²/s.

• <150 pCi/g of any other NORM radionuclide in soil or nonsoil media, averaged over any 100 m² and averaged over the first 15 cm below the surface.

Exempt Materials and Equipment

• Radiation exposure level <50 mR/hr at any accessible point, including the background radiation level.

Surface Contamination

• Average <5000 dpm per 100 cm² over the entire measured surface.

• <15,000 dpm per 100 cm² in an area <100 cm², notwithstanding the aforementioned limit.

• Removable contamination <10 dpm/cm².

Texas RegulationsIn accordance with the Texas Commission on Environmental Quality Radioactive Materials Division Document RG-486, exceptions to regulated disposal are provided as follows:

Unrestricted Use

• A site meets the unrestricted use requirement if the residual radioactivity distinguishable from background radiation:

– Results in a TEDE (total effective dose equivalent) of <25 mrem/yr (30 Texas Administrative Code [TAC] 336.603).

– Is <5 pCi/g of 226Ra or 228Ra, averaged over any 100 cm² and the first 15 cm of soil below the surface.

– Is <15 pCi/g of 226Ra or 228Ra, averaged over any 100 cm² and each subsequent 15 cm layer of soil.

Surface Contamination Exemptions (30 TAC 336.364, Appendix G)

Radionuclide Average Maximum RemovablenatU, 235U, 238U, and Associated Decay Products Except 226Ra, 230Th, 227Ac, and 231Pa

5000 dpm α per 100 cm²

15,000 dpm α per 100 cm²

1000 dpm α per 100 cm²

Transuranics, 223Ra, 224Ra, 226Ra, 228Ra, natTh, 228Th, 230Th, 232Th, 232U, 231Pa, 227Ac, 90Sr, 125I, 126I, 129I, 131I, and 133I

1000 dpm per 100 cm²

3000 dpm per 100 cm²

200 dpm per 100 cm²

β- emitters (radionuclides with decay modes other than α emission or spontaneous fission) except 90Sr and others noted above

5000 dpm β- per 100 cm²

15,000 dpm β- per 100 cm²

1000 dpm β- per 100 cm²

Disposal Exemptions (25 TAC 289.259[d])

• <30 pCi/g of 226Ra or 228Ra if the radon emanation rate is <20 pCi/m²/s.

• <5 pCi/g of 226Ra or 228Ra if the radon emanation rate is >20 pCi/m²/s.

• <150 pCi/g of any other NORM radionuclide.

226Ra and 228Ra are considered separately, so both isotopes can be up to the limit (30 or 5 pCi/g) and still be exempt.

Texas does not allow dilution for reduction of the radioactive concentration so that the waste classification is lowered or disposal requirements lessened (30 TAC 336.229).

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Texas Regulations (continued) Burial • May dispose of oil and gas NORM waste by burial at the same site where the oil and gas NORM waste was generated provided that, prior to burial, it has been treated or processed to <30 pCi/g 226Ra and 228Ra or <150 pCi/g of any other NORM radionuclide.

Landfarming • May dispose of oil and gas NORM waste at the same site where the oil and gas NORM waste was generated by applying it to and mixing it with the land surface, provided that after such application radioactivity <30 pCi/g 226Ra and 228Ra or <150 pCi/g of any other radionuclide.

Injection • Injection by a licensed operator of oil and gas NORM waste that meets exemption criteria is authorized.

Equipment/Material Exemptions

• Radiation exposure level, including the background radiation level, <50 mR/hr at any accessible point (25 TAC 289.259[d][3]).

• Natural gas, natural gas products, crude oil, and crude oil products containing NORM are exempt (25 TAC 289.259[d][7]).

• Produced waters from oil and gas production are exempt if the produced waters are reinjected into an approved well (25 TAC 289.259[d][8]).

Product Exemptions

• Phosphate and potash fertilizer (25 TAC 289.259[d][6]).

• Phosphogypsum for agricultural uses (25 TAC 289.259[d][6]).

• Building construction materials, if they contain unconcentrated NORM (25 TAC 289.259[d][6]).

• Industrial processing, sandblasting, metal casings, if they contain unconcentrated NORM.

• By-products from fossil fuel combustion (bottom ash, fly ash, and by-products of flue gas emission control).

West Virginia RegulationsIn accordance with the West Virginia Code, exceptions to regulated disposal are provided as follows:

Exempt with respect to any combination of 226Ra and 228Ra if:

• <5 pCi/g excluding natural background.

Shall not transfer or release for unrestricted use:

• Equipment contaminated with TENORM with a surface gamma radiation level >100 mrem/hr including natural background.

• Land where the concentration of 226Ra or 228Ra in soil averaged over any 100 m² exceeds the background level by more than 5 pCi/g averaged over any 15 cm below the surface.

Wyoming RegulationsIn accordance with Wyoming Department for Environmental Quality Water Quality Division regulations, the Oil and Gas Conservation Commission does not have specific NORM regulations; however, the Department for Environmental Quality Water Quality Division regulates the presence of radium in produced water that is discharged into surface water.

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CONCLUSIONS AND

RECOMMENDATIONS

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The Current Regulatory Predicament• Adequate characterization of the radionuclide

concentration has been a major limitation of most NORM risk assessments conducted to date.

– To determine hazards from radiation, one must know not only the activity level of the material, but also the type of radiation

emitted (, , ) and the total amount of energy that is deposited by the radiation in tissue or organs.

– No field-deployable instrument is currently capable of measuring isotope activity concentration directly and accurately.

A Few EERC Opinions • North Dakota should continue its efforts to enable

and actively promote carefully designed in-state solutions for NORM waste disposal:

– Injection wells

– NORM waste-receiving landfills

• All involved parties should redouble efforts to educate the public and each other about NORM science. Radiation can be used as an emotional word if the science of radiation is not conveyed accurately and simply.

– Inadequate information exists on NORM- contaminated inventories because of this measurement problem.

• Most state regulations focus on activity level alone. The regulations are written to set thresholds on the activity level of specific isotopes.

• Therefore, regulations are difficult or impossible to enforce or responsibly employ.

• Regulations suggested by CRCPD Part N are difficult or impossible to enforce by regulators or employ by responsible industry. Therefore, North Dakota should consider a departure from the Part N template to permit regulators and the oil and gas industry to responsibly and efficiently determine disposition of NORM wastes.

• To determine appropriate thresholds (units and magnitudes) in regulations, industry and the North Dakota Department of Health should work together to determine what measurements can be made routinely in the field and what threshold values of those measurements pose a true public health hazard.

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For More Information, ContactJohn A. Harju Associate Director for Research(701) [email protected]

Jay C. AlmlieSenior Research Manager (701) [email protected]

Energy & Environmental Research Center15 North 23rd Street, Stop 9018 Grand Forks, ND 58202-9018

www.undeerc.org

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