1. What is Naturally Occurring Radioactive Material (NORM)?
NORM is natural material that contains primordial radionuclides, typically those associated with uranium and thorium. For example, Uranium-238 has a half-life of about 4.5 billion years, or approximately the age of the earth, and Thorium-232 has an even longer half-life of about 14 billion years. These radionuclides are present in the rocks, soil, and minerals around us.
2. What is TENORM?
If the natural concentrations or radionuclide distributions are enhanced by human activity and technology, technologically enhanced NORM (or TENORM) is produced.
3. Is NORM/TENORM associated with oil & gas exploration and recovery?
Yes, NORM and TENORM are present in oil & gas fields. This has been well known since the early 1980s; however, the concentration of the associated radionuclides is highly dependent on the local geology. Operational wastes from hydraulic fracking will also contain NORM.
4. Should I be concerned about something I can’t see, hear, smell, or feel?
Yes, because the radionuclides in NORM produce ionizing radiation. Simply put, ionizing radiation is energy. The energy from radiation produces ions in the material it encounters, including cells in the human body. These ions can alter living cells. At relatively high doses, one potential outcome of exposure to ionizing radiation is cancer, making radiation a carcinogen.
5. Who regulates NORM in oil & gas fields?
In the United States, the regulatory authority for NORM/TENORM lies largely with the States, not the federal government. No federal statute is specifically designated for regulating NORM, and the scientific or technical basis for regulating NORM has not been well established. Thus, state-by-state regulation of NORM is inconsistent. As a result, individual states have to cope with the emerging radiological issues of NORM/TENORM on an ad hoc basis with little scientific support.
6. Is NORM a solid waste management issue for oil & gas exploration and recovery?
Yes. Many states have specific regulations that prohibit disposal of radioactive materials, from any source (man-made or natural), in any concentration, in sanitary or industrial landfills. At a minimum, waste containing NORM may be rejected by a landfill. At a maximum, if waste is improperly disposed, remediation (removal) of the waste from the landfill under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) may be required. There may be fines and/or imprisonment penalties for the producers of the waste if CERCLA remediation is required. This may be in addition to the expense of litigation.
7. Is NORM a waste water management issue for oil & gas exploration and recovery?
Yes. Although NORM is only one of many potential constituents in oil & gas waste water, treatment or disposal of water containing NORM may be very difficult, and often results in the generation of radioactive solid waste.
8. Is the radiation from NORM a hazard for oil & gas field workers?
Maybe; it depends on the concentrations and quantities encountered. Although the concentrations of NORM are low enough that immediate effects — such as reddening of the skin, hair loss, or decreased white blood cell counts — do not occur, some believe that low level occupational radiation doses, such as those that may be caused by oil and gas industry TENORM, could increase one’s lifetime risk of cancer. The actual magnitude of increased cancer risk is likely to be extremely small. The fear of elevated cancer risk may result in litigation for individuals who develop cancer later in life.
9. Is NORM an environmental protection issue for oil & gas exploration and recovery wastes?
Yes. If improperly identified or managed, NORM in oil & gas exploration and production legacy waste may require remediation by the waste generator under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
10. How can I be sure that the levels of NORM materials at my oil & gas operation are “safe?”
Unlike most carcinogens or toxins, radiation is easily detected in most situations with reliable hand-held radiation detection instruments. It is relatively easy to develop radiation survey methods and training programs to ensure workplace safety and to ensure that waste containing elevated levels of NORM are safely disposed.
Questions?
If you have questions about this information or need assistance for your company, facility, or project, please feel free to contact us.