Amy Dalrymple, Forum News Service, Published November 24 2013
Radioactive waste comes to the surface
But the waste does show up in illegally in North Dakota landfills as some companies try to avoid the expense and time it takes to properly transport the waste out of state.
North Dakota’s top oil and gas regulator says the naturally occurring radioactive waste (NORM) associated with oil production will become an even greater issue for the Bakken as development continues.
“Now is the time to really work this out,” said Lynn Helms, director of the state Department of Mineral Resources.
It’s costly to transport the waste out of state, which has led to cases of illegal dumping. North Dakota is considering creating new rules on the material, including accepting waste with higher levels of radiation or injecting it deep into the earth.
NORM is present underground and is brought to the surface as a result of oil and gas production. Also referred to as technologically enhanced NORM, or TENORM, it’s often found in oil production wastes such as drilling mud, pipe scale and other wastes.
North Dakota landfills can’t accept waste with radioactivity levels above 5 picocuries per gram, requiring the material to be disposed of in states such as Colorado, Idaho, Texas and now Montana.
Filter socks, which look like large tube socks and are used in saltwater disposal wells to filter out the solids, contain NORM and have been discovered illegally in municipal landfills and ditches, including the Fort Berthold Indian Reservation and near the entrance of Theodore Roosevelt National Park.
“There’s no effective tracking mechanism to know that it went out of state and it actually went where it was supposed to go,” Helms said. “There’s a good argument for creating a system within North Dakota to track it and know it’s gone to a properly licensed disposal.”
Helms estimates the industry generates 75 tons of waste containing NORM each day.
Laura Erickson, a Williston consultant who is certified to teach a course on NORM, estimates that the state’s saltwater disposal wells need to dispose of between 19 million and 169 million filter socks each year.
“There are operators out there who are stockpiling the stuff because either they don’t know what to do with the waste or it’s too expensive,” said Erickson, owner of Plains Energy Technical Resources.
Incidents of radioactive material showing up at municipal landfills had decreased for a while, but the North Dakota Department of Health received more reports again this fall, said Scott Radig, director of the Division of Waste Management.
Radig said he believes the cases of illegal dumping are coming from a handful of operators that are trying to save money, while most companies have complete record-keeping systems for tracking how it’s handled.
“My sense is the vast majority of companies are doing it right,” Radig said.
Trucking it out of state, however, does carry a certain level of risk and uncertainty about whether it arrived at the right place, he said.
If a municipal landfill rejects a load because it contains NORM, the health department is notified and makes follow-up phone calls to find out where it went, Radig said. But since the load is headed out of state, the department’s ability to verify where it went is limited.
“It’s difficult for us to physically follow up with anything like that,” he said.
The health department has contracted with Argonne National Laboratory in Illinois to evaluate potential risks of disposing of certain concentrations of NORM in North Dakota landfills, Radig said.
The study will look at the risks from NORM generated in the oilfield and the engineering and design standards for landfills in North Dakota, Radig said.
“We’re looking at what would be a safe manner of handling and disposal here in North Dakota,” Radig said.
The cost of the study, about $182,000, will be funded by the health department, Radig said. The final report is expected to be done at the end of summer 2014, he said.
Two groups, the Energy Industry Waste Coalition and the Dakota Resource Council, have opposed raising the level of waste that can be accepted and have urged the public to report cases of illegal dumping.
Montana will accept waste containing NORM up to 30 picocuries per gram in landfills that are constructed to certain standards, said Rick Thompson, solid waste section supervisor for Montana’s Department of Environmental Quality.
The state set the limit at 30 after researching the issue, including consulting with other states and Canada, Thompson said.
“The 30 picocurie level will not cause acute impacts to someone who is exposed to it on a somewhat infrequent basis,” said Thompson, referring to truck drivers who would come in contact with the facility. “It would take a long time to be exposed at that level to get sick.”
One landfill in eastern Montana has been permitted to accept waste at that level and a second facility is proposed just across the border from Williston.
The Energy and Environmental Research Center at the University of North Dakota is studying disposal options and best practices for handling NORM waste with funding from oil companies.
Jay Almlie, senior research manager, said the industry wants to take a careful look at how to deal with NORM responsibly. The study will take an inventory of how much and what kind of NORM is being generated in North Dakota and what regulations would be reasonable and supported by science, Almlie said.
One option being studied is to dispose of NORM waste by injecting it in wells that are in the Mission Canyon formation, about 6,000 to 8,500 feet below ground, Helms said.
“The material ends up below some of our salt layers so it’s physically impossible for it to show up on the surface again,” Helms said. “As it decomposes, any radon that it would generate would also be trapped down there and would have no opportunity to get to the surface.”
Another advantage to disposing it underground is it would have less impact on the surface, Helms said.
Disposing NORM waste through deep-well injection is already approved by the Environmental Protection Agency and under North Dakota regulations, Radig said.
“That’s generally considered very low risk because it’s thousands of feet below the ground surface,” Radig said. “It’s probably the safest way to dispose of it.”
An injection well would need a permit from the North Dakota Industrial Commission.
Even if North Dakota does not change its disposal limit, the state will likely adopt new NORM regulations such as rules on record keeping and storage and handling practices, Radig said.
The federal government does not have regulations related to NORM, other than requirements the Occupational Safety and Health Administration has to protect workers, Erickson said.
States such as Alaska, Arkansas and Texas have regulations regarding handling and other rules specific to NORM, while North Dakota’s only rule relates to the disposal limit, Erickson said.
The North Dakota Department of Health needs to do more public education about NORM, Radig said.
“I think there’s a certain emotional reaction that people have anytime the word radiation or radioactivity is used, it kind of brings up pictures of the nuclear disaster that happened in Japan,” Radig said. “NORM is really a completely different issue. It’s not anything like the material that’s in a nuclear power plant.”
The EERC says common household items contain radioactivity, including cat litter than measures at 5 picocuries per gram, a brazil nut that measure at 6 picocuries per gram and a granite countertop that measures at 27.
“Unless you’re in extremely close proximity to it for extended period of time, there really is no elevated level of risk to the general public,” Radig said.
Helms called the risk to the general public “really, really low.”
“The type of radiation that it gives off is blocked by clothing or almost anything, so you have to ingest it either by eating or swallowing something that has the NORM in it or breathing it in,” helms said. “You have to ingest it before it presents any health risks. If you’re not physically handling it yourself, there really is no risk.”
Erickson said it is important for the industry to get a handle on managing the waste now because as wells and facilities age, they will produce more.
“It’s not like Chernobyl, but it is waste that has to be managed properly,” Erickson said.