NORM (Naturally Occurring Radioactive Material)
Jurisdiction over oil and gas waste containing naturally occurring radioactive materials (NORM) is split between the Texas Department of State Health Services (DSHS) and the Railroad Commission. The DSHS regulates the possession, use, transfer, transport, and storage of NORM and the Railroad Commission regulates the activities associated with disposal of oil and gas NORM waste.
RRC-permitted NORM disposal facilities:
There are currently no RRC-permitted commercial landfills or disposal pits authorized to dispose of NORM waste.
Commercial injection/disposal wells permitted to dispose of NORM can be found using the Injection & Disposal Query on our webpage. To search for a permitted NORM disposal facility:
- Use the query tool (http://webapps2.rrc.texas.gov/EWA/uicQueryAction.do)
- Under “Permitted Fluid,” select “NORM.”
- Under “Special Conditions,” select “Commercial.”
- Click on “Submit” to generate results.
- Note that there are currently approximately 10 facilities in three districts that are permitted for NORM disposal, so adding additional criteria to the search may cause search results to be empty.
NORM in the Oil and Gas Field
NORM encountered in oil and gas exploration, development and production operations originates in subsurface formations, which may contain radioactive materials such as uranium and thorium and their daughter products, Radium 226 and Radium 228. NORM can be brought to the surface in the formation water that is produced in conjunction with oil and gas. NORM in these produced waters typically consists of the radionuclides, Radium 226 and 228. In addition, Radon gas, a radium daughter, may be found in produced natural gas.
Because the levels are typically low, NORM in produced waters and natural gas is not a problem in Texas unless it becomes concentrated. Through temperature and pressure changes that occur during oil and gas production operations, Radium 226 and 228 found in produced waters may co-precipitate with barium sulfate scale in well tubulars and surface equipment. Concentrations of Radium 226 and 228 may also occur in sludge that accumulates in oilfield pits and tanks. These solids become sources of oil and gas NORM waste. In gas processing activities, NORM generally occurs as radon gas in the natural gas stream. Radon decays to Lead-210, then to Bismuth-210, Polonium-210, and finally to stable Lead-206. Radon decay elements occur as a film on the inner surface of inlet lines, treating units, pumps, and valves principally associated with propylene, ethane, and propane processing streams.
Workers that conduct activities such as cutting and reaming oilfield pipe, removing solids from tanks and pits, and refurbishing gas processing equipment may be exposed to particles containing levels of alpha-emitting radionuclides that could pose health risks if inhaled or ingested.
| Microroentgens per hour- µR/hr |
A measure of exposure from X-ray and gamma ray mR/hr radiation in air. Measurement of the intensity of radiation in air. A microroentgen = one millionth of a roentgen. |
| Picocuries per gram- pCi/g |
A measure of the radioactivity of one gram of radionuclide that decays at a rate of 3.7E-2 disintegration per sec. |
| MilliREM- mREM/yr |
An acronym for roentgens equivalent man. Relates to the adsorption of radiation on parts of the body over time. One REM ~ One Roentgen. |
Radiation Limits and Comparisons
| For protection of public: |
100 mRem/yr
|
| For radium in water: |
30 pCi/liter
|
| For radium in drinking water: |
5 pCi/liter
|
| EPA suggested action level for radon in residences: |
4 pCi/liter
|
State Regulation
Railroad Commission Regulations for Disposal of Oil and Gas NORM
The Commission regulates the disposal of oil and gas NORM under Environmental Protection, Subchapter F, Oil and Gas NORM. Subchapter F establishes the requirements for oil and gas NORM waste disposal. Oil and gas NORM waste is defined as any solid, liquid, or gaseous material or combination of materials (excluding source material, special nuclear material, and by-product material) that spontaneously emits radiation in its natural physical state, is discarded or unwanted, constitutes, is contained in, or has contaminated oil and gas waste, and exceeds the exemption criteria specified in 25 Texas Administrative Code §289.259(d)(1)(B) and (d)(2) prior to treatment or processing that reduces the radioactivity concentration.
Anyone who owns or operates equipment used for production or disposal (including waste storage tanks) must identify NORM-contaminated equipment with the letters "NORM" by securely attaching a clearly visible waterproof tag or marking with a legible waterproof paint or ink. Employers whose employees speak languages other than English may add to the tag the translation of the acronym "NORM" in those languages as long as the acronym "NORM" is also on the tag.
Facilities with oil and gas surface waste disposal permits that require financial security are required to conduct a NORM screening survey of the facility when submitting a closure cost estimate (CCE) for permit renewal. If NORM is detected at the facility above the screening level, the CCE must include additional costs for disposal of NORM-contaminated equipment, soils, or waste. For guidance on conducting a NORM screening survey, see our Closure Cost Estimate Guidance.
| Screening limit | 50 µR/hr |
| Radium-226 combined with Radium-228 | 30 pCi/g |
| Any other radionuclide | 150 pCi/g |
Subchapter F contains exclusions from certain activities, exemptions for certain disposal activities, and prohibitions against certain activities. Subchapter F also authorizes certain disposal methods and requires a permit for others.
The activities excluded from Subchapter F are activities that are regulated by the Texas Department of State Health Services (DSHS). These excluded activities include:
- recycling activities,
- decontamination of equipment (unless the contamination is only as a result of disposal activities,) and
- possession use, transfer, transport, and/or storage (unless this occurs at a disposal site and occurs to facilitate disposal.)
The disposal activities exempt from Subchapter F include:
- disposal of produced water by injection into a well permitted under §3.9 (relating to Disposal Wells) or §3.46 (relating to Fluid Injection into Productive Reservoirs) is exempt
- disposal of equipment that has been decontaminated by a specific licensee following the DSHS regulations for decontamination and that meets the exemption criteria of §289.259 is exempt
The disposal activities prohibited by Subchapter F include:
- spreading of oil and gas NORM waste on public or private roads, and
- disposal by any other method not specifically described by Subchapter F.
Disposal Options:
Subchapter F contains permit requirements and standards for those disposal methods requiring a permit. Permits for disposal of oil and gas NORM waste by underground injection are issued under Rule 9. Permits for surface disposal of oil and gas NORM waste are issued under Rule 8. Permits for disposal of oil and gas NORM will have requirements necessary to protect public health and the environment.
NORM-Contaminated SolidsNORM-contaminated solids, such as pipe scale, may be disposed of without a permit on the site where they were generated:
- by placement in a well that is being plugged and abandoned
- by burial, provided that prior to burial, the radioactivity concentration does not exceed exemption levels
- by landfarming, provided that after application and mixing, the radioactivity concentration does not exceed exemption levels.
Subchapter F also authorizes disposal of oil and gas NORM waste at licensed facilities. NORM waste may be disposed of by injection if it is treated by a DSHS specific licensee following specific requirements contained in the rule.
NORM-Contaminated EquipmentNORM-contaminated equipment that is waste, such as equipment that is no longer wanted, may be decontaminated and recycled as scrap metal under DSHS regulations or disposed of. Scrap metal dealers routinely screen for gamma radiation and reject scrap at their selected µR/hr settings.
Equipment must be decontaminated if it is to be released for unrestricted use (for some purpose other than for oil and gas activities). Subchapter F does not allow the burial of NORM-contaminated equipment. However, buried flow lines that contain NORM may remain buried contingent on the lease agreement. NORM-contaminated tubulars and other equipment may also be placed in a plugged and abandoned well. The Commission’s Statewide Rule 14 (§3.14), relating to well plugging, require equipment to be removed from a lease when the last well on the lease is plugged. Rule 14(d)(12) requires all tanks, vessels, related piping, and flow lines be emptied, and requires all tanks, vessels, and related piping to be removed in 120 days. NORM-contaminated equipment must be decontaminated, and NORM waste and equipment must be properly disposed of when a lease is abandoned.
Texas Department of State Health Services (DSHS) regulations for NORM
The Texas Department of State Health Services (DSHS) regulates radiation protection standards for the possession, use, transfer, transport, and/or storage of NORM or the recycling of NORM-contaminated materials under 25 TAC §289.259.
Any person who possesses NORM above the exemption levels is a general licensee under the DSHS regulations. Operators have a duty to determine whether they possess NORM above the exemption levels. The DSHS regulations require a specific license to perform decontamination work.
The DSHS NORM regulations contain special worker protection requirements for oilfield workers. These requirements generally address worker hygiene and vessel entry.
The DSHS regulations are based on risk assessment of NORM waste and NORM-contaminated equipment. The regulations include exemption criteria for NORM-contaminated soils, materials in the recycling process, and equipment. In addition, the following are exempt from the DSHS regulations:
- possession, storage, use, transportation, and commercial distribution of natural gas and natural gas products and crude oil and crude oil products containing NORM
- possession of produced water containing NORM.
Oil and gas waste with radioactivity at levels above the exemption levels are considered oil and gas NORM wastes. Oil and gas NORM wastes must be managed in accordance with the Commission’s NORM disposal regulations. Transfer of NORM-contaminated equipment is allowed provided the equipment is used in oil and gas operations. However, NORM-contaminated equipment that is being discarded must be decontaminated before it is disposed of or sent to a scrap recycling facility.
Survey of NORM at Texas Leases and Facilities
In 1999-2000, RRC Staff performed field surveys to measure levels of NORM in equipment at production leases and associated oilfield facilities. The results of the survey are summarized in a table format at this link: NORM Field Measurements.
Of the 612 sites surveyed, only 59 sites had equipment with readings above 50 µR/hr, the limit above which the equipment cannot be released for unrestricted use (use for purposes other than oil and gas activities.). Out of over 5900 readings, only 203 readings were above 50 µR/hr. Specific geographic areas tend to have elevated NORM levels.
