Risk-Based Regulation of Oil and Gas

NORM Waste Management

Alternatives

K.P. Smith, J.J. Arnish, G.P. Williams, D.L. Blunt, and

H.I. Avci

Environmental Assessment Division

Argonne National Laboratory

A U.S. Department of Energy

Office of Science Laboratory
Office of Science
U.S. Department of Energy Operated by The University of Chicago
How Has the NORM Issue Evolved in the U.S.?

• Industry was aware of NORM in the U.S. as early as the 1930s.

• Concern about the potential health risk did not develop until
the early 1980s.

• Regulatory controls were first established around 1984 and

enacted by individual states.

• Regulations were intended to reduce health risks associated

with NORM, although without detailed risk assessments.

• Subsequently, the results of waste analyses and risk

assessments were incorporated into state regulations.

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How is NORM Regulated in the U.S.?

• At the state level only

• Eleven states currently have specific NORM rules – five of these
states have significant levels of oil and gas activity

• Regulations establish
- Exemption levels,
- Management requirements, and
- Disposal requirements

• Variability exists among the state regulations

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Exemption Levels For Loose Wastes and Soils
Have “Evolved” In Some States
• Initially, NORM exemption levels were derived from preexisting
standards.
- e.g., the USEPA standards for uranium and thorium mill tailing sites

• Known as the “5/15 rule.”

- 5 pCi/g (0.185 Bq/g) in the top 15 in. of soil
- 15 pCi/g (0.56 Bq/g) in subsequent 15 in.-thick layers of soil
• This standard may be overly restrictive (and expensive) for
petroleum industry NORM wastes.

• Several states have adopted 30 pCi/g (1.1 Bq/g) for wastes that
have a low radon emanation rate.

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NORM Regulations Have Limited the Number
of Approved Disposal Options
• Initially, states allowed a limited set of disposal options:
- Land disposal facilities licensed for radioactive wastes
- Plugged and abandoned wells
- Other methods to be approved on a case-by-case basis
• Over time, additional disposal options have been approved:
- Underground injection
- Land disposal facilities licensed for nonhazardous wastes
- Landspreading
• Limited disposal options translate into increased costs.
• This is a reasonable outcome, as long as the potential risk
warrants the extra costs.
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Pathway Analysis Supports Establishment of
Risk-Based Disposal Regulations
Environmental Exposure Dose or
Source Pathway Pathway Cancer Risk
On-Site External
Direct Exposure Radiation

On-Site Air Dust/

Concentration H-3
Radon

Inhalation
Plant Foods Effective
Dose
Equivalent/
Excess
On-Site Water Cancer Risk
Contamination to an
Exposed
Individual
Livestock Meat

Milk

Ingestion
Aquatic
Foods

On-Site Soil
Contamination
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Underground Injection Analysis
• Exposure pathway of concern: consumption of contaminated
groundwater

• Assumed worst-case scenario

 Casing failure during injection in the shallow aquifer
 NORM dissolved instantaneously
 Conservative values used for groundwater gradient,
hydraulic conductivity, and porosity
 Closest receptor 0.3 km downstream
Injection
Well

• Both generic and site-specific

situations have been modeled
 Generic case: 100,000 bbl of waste
containing 74 Bq/g of Ra-226
Radium in solution
Precipitated radium

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Estimated Doses for Underground Injection
Present Negligible Risk

Annual Dose (mSv) at Receptor

Location Relative to Disposal Site
Depth of Failure in
Drinking Water Aquifer 0.0 km 0.3 km 0.8 km
90 m – 0.01 2 x 10-3
275 m 2 x 10-3 1 x 10-3 4 x 10-4
450 m 1 x 10-4 1 x 10-4 8 x 10-4

These estimates are well below the ICRP-recommended

dose limit of 1 mSv/yr from all man-made sources.
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Disposal in Nonhazardous Landfills

• Case study evaluated disposal of

 2,000 m3 of bulk waste containing 50 pCi/g of radium
 20 m3 of bulk waste, average concentration of 260 pCi/g of Pb-210

• Case study based on municipal landfill in Michigan

 Landfill design and operation
 Institutional controls
 Local population density
 Subsurface conditions

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A Variety of Receptors and Pathways Were
Modeled for Landfill Disposal

Operational Phase Receptors Future Use Receptors

 Driver  On-site resident
 Waste placement operator  On-site industrial worker
 Leachate worker  Recreational visitor
 Off-site residents  Off-site resident
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Estimated Doses for Landfill Disposal Present
Negligible Risk
Dose
Receptor (mSv/yr) Risk
Operational Phase Scenarios
• Provided that:
Driver 0.003 -7  Landfill
controls
1 x 10
Waste-placement operator 0.017 -7 were maintained
7 x 10  Wastes were
Leachate worker -6 -11
2.2 x 10 8 x 10 more than 3.3 m
Off-site resident -6 -10 deep
6.6 x 10 3 x 10
General population (80-km) -7 -8
2.7 x 10 1 x 10
Future Use Scenarios
On-site resident 0.074 -6
4 x 10
On-site industrial worker 0.022 -6
1 x 10
Recreational visitor -9 -14
1.2 x 10 6 x 10
Off-site resident -6 -10
3.2 x 10 2 x 10
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Landspreading Disposal
• Evaluated potential doses for a variety of receptors and
pathways of concern

• Assumed reasonable yet conservative parameters

defining the landspreading operations
 2-acre (0.8-ha) tract of land
 0.2 m-thick contaminated
zone
• Calculated doses on a per
unit basis

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Estimated Doses Indicate Landspreading May
Result in Unacceptably High Doses
Residential Scenario Industrial Use Scenario
Worker Recreational Use
Agricultural Scenario

1000

100

10
mSv/yr

0.1

0.01

0.001

0.0001
0.01 0.1 1 10 100 1000
Resultant Ra-226 Soil Concentration (Bq/g)

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Summary Remarks

• Disposal alternatives that provide a high degree of

isolation of the wastes (e.g., landfill disposal and
underground injection) present acceptably low levels of
risk to workers and the public, provided certain conditions
are maintained.

• Site-specific analyses are required to fully assess the

potential risks and to ensure that adequate controls are in
place.

• NORM regulatory schemes should pursue the

development of risk-based exemption levels and disposal
regulations to ensure adequate protection of human health
at the lowest possible economic impact.

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