Communication, Education Key To Discussions About Radioactive E&P Waste
Naturally occurring radioactive material from deep in the Earth is sometimes a byproduct of exploration and production (E&P) in the oil and gas industry. Although some experts say currently produced levels are not a cause for concern, Alex Wagner of Buckhorn Energy and Robert Morris, a radiation safety expert with M.H. Chew and Associates, are working to stay ahead of the curve and educate the public about technologically enhanced, naturally occurring radioactive materials (TENORM).
Wagner and Morris have analyzed recent developments in the management of TENORM. “Right now is a very confusing time,” Wagner said. “The industry as a whole, and regulators, are just starting to learn how to manage this problem.”
“We need to be regulating smartly,” he added, pointing to the public’s generally limited understanding of radiation and the resulting fear, which he called “radiophobia.”
“It’s imperative that the public understand how their regulators with the help of the industry are managing this waste stream,” Wagner said. “We hope that we can address current and future concerns with fact-based discussions rather than rumor or misinformation.”
“The fracturing debate is a good analogy,” he said. “The public is in arms over fracturing, as a result of the lack of publicly available information regarding the process. The oil and gas industry’s attempt to address this has been met with mixed results, likely because it came too late.”
The Pennsylvania Department of Health recently reported preliminary findings of its nearly 2-year-long effort to understand the exposure potential for TENORM. The report can be read here. The report is being revised and will be reissued later this year.
One thousand samples were analyzed from drill cuttings, muds, proppants, sludges, soils, sediments, and flowback and produced water. Natural gas was sampled for radon, and exposure-rate surveys were made on equipment and at operator locations.
The results of the study show that wellsites have low worker-exposure potential but that the potential exists for environmental impact from spills. The majority of conclusions from the report say that more study is needed. “Science is paramount here,” Morris said. “You have to understand what you have before you can regulate it.”
North Dakota is making news for its proposed rulemaking that would allow landfill operators to apply for increased concentration limits for TENORM in existing E&P landfills. Currently, the North Dakota concentration limit is 5 pCi/g, including background. The proposed limit is 50 pCi/g. Argonne National Laboratory prepared a study for the state in order to establish the safety basis for the proposed limit, which can be found here.
A patchwork of regulations covers TENORM, Wagner and Morris said. With a few exceptions including hazardous material transportation, diffuse TENORM, the kind found in E&P waste, is not regulated by the US government because the authority is reserved for states under the Atomic Energy Act.
Because the regulatory, industrial, and public-interest factors vary, the regulations are different in each state. Many states, for example, North Dakota, allow TENORM to be disposed in landfills only if the concentration is less than 5 pCi/g. Montana has a similar rule except for specially permitted landfills that accept E&P waste with total radium concentrations of up to 30 pCi/g. A large fraction of the waste from the Bakken formation is being disposed in eastern Montana.
Texas allows TENORM waste with total radium concentration of up to 30 pCi/g to be disposed in any E&P landfill. Since 1996, Michigan has allowed any landfill to accept TENORM of up to 50 pCi/g. The Michigan limit was reviewed by the state’s TENORM Disposal Advisory Panel. Its recent report, which can be read here (PDF), endorsed the current limit and provided several other recommendations.
“Every state is taking a different approach and learning different things,” Morris said. “The problem is managed as a function of the hazard. In Pennsylvania, it’s a big deal. In Wyoming, it’s not.”
“The bottom line,” he said, “is that you cannot come up with a scenario that approaches a danger point for the public. There are a few workplace situations, especially during natural gas pipeline maintenance, in which workers could be exposed to important levels of radioactive materials. Proper management is necessary to ensure TENORM does not create an environmental and long-term health hazard, and communication is a key to success. TENORM is not nuclear waste from reactors or weapons, and it is a mistake to let any misconception go unanswered.”