Regulators talk TENORM
Representatives from industrial and public entities alike gathered Tuesday in Dickinson to learn more about new radioactive oilfield waste regulations that include a 10-fold increase in the level of acceptable radioactivity in waste disposed in s...
Representatives from industrial and public entities alike gathered Tuesday in Dickinson to learn more about new radioactive oilfield waste regulations that include a 10-fold increase in the level of acceptable radioactivity in waste disposed in special North Dakota landfills.
Officials from the North Dakota Department of Health and the North Dakota Industrial Commission, as well as a representative of a private analytical laboratory, gave a series of lectures to shed light on how radioactivity pertains to oilfield waste and how oilfield waste like technologically enhanced naturally occurring radioactive materials, or TENORM, is now regulated.
Scott Radig, state Department of Health Division of Waste Management director, said
the purpose of the workshop series, which will be in Watford City today and in Williston on Thursday, is to explain new rules put into effect Jan. 1 to “anyone who’s interested in getting the information.”
“I think we’re hoping that people come away with a better understanding of how comprehensive our rules are,” Radig said. “Our whole goal throughout this process has been to ensure public safety, and we’ve followed the best science out there to do that.”
Radig said the new rules could affect a wide swath of the Oil Patch. The workshop’s target audience ranged from producers, transporters and disposers of TENORM to county officials and emergency managers.
The event included many logistical items that outlined industry obligations and potential best practices for tasks like licensing and permitting for haulers and processors and necessary recordkeeping and reporting. It also covered surveying and sampling for radioactive materials, regulatory jurisdiction in the oilfields and general radioactive safety.
Producers generate naturally occurring radioactive materials through the drilling process when dredging up mud and water that contain radioactive isotopes. When such materials are concentrated through human means, such as in a filter sock, the waste becomes known as TENORM.
Radig said one of the biggest rule changes that went into effect this year is a tracking system that follows waste from generation to disposal. Another major change was the raising of the state radioactivity disposal level to up to 50 picocuries per gram, which is 10 times higher than the previous limit, to facilitate TENORM disposal in special waste landfills.
Diana Trussell, an environmental engineer for the state health department’s Solid Waste Program, said the TENORM rules adopted this year did not automatically increase the limit in existing landfills.
“No one has completed the application process for that and no one was grandfathered in,” Trussell said, adding the increase only applies to oilfield special waste landfills and the state’s large-volume industrial waste landfill in Sawyer. The rules also prohibit TENORM from entering any of the state’s municipal and inert waste landfills.
Eligible landfills interested in raising their limits would have to apply for a major permit modification before accepting TENORM, Trussell said, and would be held to a maximum allowed tonnage of 25,000 tons per year and a maximum concentration of 50 picocuries per gram.
Mark Franks, Buckhorn Energy Services area landfills manager, said he came to the workshop to familiarize himself with the new TENORM regulations.
Buckhorn Energy, a Colorado-based gas and oilfield waste disposal and treatment services company, currently operates special waste landfills near Williston and Glendive, Mont., called Dishon Disposal, Inc. and Oaks Disposal Services LLC, respectively.
While the Montana facility can already accept wastes up to 50 picocuries per gram, like TENORM, the Williston landfill is still only permitted for the old North Dakota limit of 5 picocuries.
Buckhorn Energy leaders are still determining whether they’ll apply for a new permit to raise the limit at Dishon Disposal.
“We’ll see when the market comes back a little stronger, what the numbers look like,” Franks said, adding that the state’s special waste landfill permit fees and regulations could make the process expensive. “Obviously there’s a market there and it’s a guessing game for how much material is out there. For us, having a disposal 100 miles away that can accept it now, we’re going to hang back and see what develops.”