EERC

Energy & Environmental Research Center ®

Putting Research into Practice

NORM Primer
INDUSTRY EDITION

NORM
SM

(naturally occurring radioactive materials)

R E S P O N S I B L E • S A F E • S E C U R E • G R O W T H
This primer is intended to provide the reader with a brief, readable summary of the breadth of
radiation science behind NORM (naturally occurring radioactive materials) regulations. Because radiation is one
of the most complex topics in physics and because biological damage due to radiation is an inexact science, it is
impossible to reduce the volume of knowledge in radiation physics to a single booklet. Therefore, this booklet is
meant to provide the reader with enough information to begin asking good questions. The opinions provided at the
end of this book are meant to foster conversation regarding prudent, logical, and beneficial oilfield NORM regulatory
language formulation. The codification of wise NORM regulations will require active participation from oil and gas
industry leaders, state regulatory bodies, radiation physicists, and field survey equipment manufacturers. It is hoped
that this booklet will serve as a start to that discussion.

This industry edition is one of three editions, each geared for different audiences, but all containing the same factual,
scientifically required basis. This industry edition is intended as a tool for producers and service providers to help
them digest this complex topic in a quick overview format. It provides the fundamental science required to make
wise decisions regarding strategies on NORM waste management and NORM waste disposal.

Jay C. Almlie
Senior Research Manager
Energy & Environmental Research Center
Table of Contents
What Is NORM?.. . . . . . . . . . . . . . . . . . . . . . . . . . .................................................................. 3

Radiation Fundamentals. . . . . . . . . . . . . . . .................................................................. 7

Handling and Disposal of NORM Wastes. .......................................................... 21

Regulation of NORM Wastes. . . . . . . . . .................................................................. 25

Conclusions and Recommendations. . ............................................................... 35

NORM Primer 1
2 NORM Primer
WHAT IS NORM?

NORM Primer 3
 NORM Defined
Naturally Occurring Radioactive Materials (NORM)
Naturally occurring radionuclides are present at varying concentrations in Earth’s crust and can be concentrated and
enhanced by processes associated with the recovery of oil and gas.

Technologically Enhanced Naturally Occurring

Radioactive Materials (TENORM)
TENORM is created when industrial activity increases the concentrations of radioactive materials or when the
material is redistributed as a result of human intervention.

North Dakota producers distinguish between true TENORM

waste and the majority of waste generated by oil production
activities.

4 NORM Primer
Potential Sources of NORM Related
to Oil Production
Some of the most common potential sources of NORM waste related to oil production activities are shown below.

Tank Sludge Pipe Scale

Drill Cuttings Drilling Mud

Used Water Produced

Filtration Water
Socks

NORM Primer 5
 Potential Sources of NORM
Source Radionuclides Characteristics Occurrence

Radium in Scales 226

Ra, 228Ra, 224Ra, progeny Hard deposits of Ca, Sr, Wet parts of production
Ba sulfates and installations
carbonates Well completions

Radium in Sludge 226

Ra, 228Ra, 224Ra, progeny Sand, clay, paraffins, Separators, skimmer tanks
heavy metals

Lead in Deposits 210

Pb, progeny Stable lead deposits Wet parts of gas production
installations
Well completions

Lead in Films 210

Pb, progeny Very thin films Oil and gas treatment and
transport

Polonium in Films 210

Po Very thin films Condensate treatment
facilities

Polonium in 210
Po Gas production
Condensates

Natural Gas 222

Rn Noble gas Consumers domain
210
Pb, 210
Po Plated on surfaces Gas treatment systems

Produced Water 226

Ra, 228Ra, 224Ra, 210Pb Large volumes in oil Each production facility
production

6 NORM Primer
 RADIATION
FUNDAMENTALS

NORM Primer 7
 Radiation Emitted by NORM
Three types of radiation are emitted by NORM:

• Alpha (α)

+ – Helium nuclei that are heavy and have a

double positive charge, which causes them
to lose their energy very quickly in matter
+ – Stopped by a sheet of paper or the surface
layer of your skin
– Considered hazardous to a person’s health
only if inhaled or ingested
Helium Nucleus (2+ charge)

• Beta (β)
– Electron, one negative charge
– – Much smaller, interacts more slowly with material
– Stopped by thin layers of metal or plastic
– Considered hazardous only if ingested or inhaled

Electron (- charge)

• Gamma ()
– Associated with alpha and beta decay and is a
form of high-energy electromagnetic radiation
that interacts lightly with matter
– Shielded by thick layers of lead or other dense
materials
– Considered an external hazard to living tissue

Gamma Photon

8 NORM Primer
Shielding for Radiation Types
Although radiation is ubiquitous in our environment, it is desirable to keep radiation exposure as low as reasonably
achievable (ALARA). This is accomplished by the techniques of time, distance, and shielding.
• Time: The less time spent in a radiation field, the less radiation exposure is received by the exposed body.
• Distance: The farther a person is from a source of radiation, the lower the radiation dose. Levels decrease by
a factor of the square of the distance. Think of it as sound. The farther you are from a jet engine, the less your
ears hurt.
• Shielding: Placing a radioactive source behind a barrier material can reduce radiation exposure.

Paper Plastic Steel Lead





Tissue

NORM Primer 9
 Radiation Units
The four different but interrelated categories of
radiation measurement are radioactivity, exposure,
absorbed dose, and dose equivalent (READ).

• RADIOACTIVITY is the amount of

ionizing radiation (, , and  x-rays or neutrons)
released by a material and represents how many
atoms in the material decay in a given time period.

• EXPOSURE is the amount of radiation

traveling through the air. Most radiation monitors
used in the oil fields measure exposure.

• ABSORBED DOSE describes the

amount of energy that radioactive sources deposit
in materials through which they pass.

• DOSE EQUIVALENT (or effective dose)

combines the amount of radiation absorbed and
the medical effects of that type of radiation. For
beta and gamma radiation, the dose equivalent is
the same as the absorbed dose. By contrast, the
dose equivalent is larger than the absorbed dose
for alpha and neutron radiation, because these
types of radiation are more damaging to the
human body.

10 NORM Primer
Units Get Confusing
• For many practical health physics problems, over
the range of energies usually encountered, the rad
(dose) and Roentgen (exposure) units are often used
interchangeably:
– One g of air will absorb 87 ergs of energy, and 1 g
of soft tissue will absorb 96 ergs of energy when
exposed to a radiation field to produce an exposure
of 1 Roentgen.
• The Roentgen is a special unit, in part, because it is used
only with  radiation.
• Generally, radioactivity units (pCi) are not convertible to
dose units (rad, rem, Sv), or vice versa.

Radioactivity
• Becquerel, Bq (SI) Specific Activity = Radioactivity
• Curie, Ci (imperial)
per Unit Mass

Exposure Radioactivity Transmitted

• Roentgen (R, for  radiation, only) Through Air

Dose
• Dose absorbed
– Gray, Gy (SI)
– Rad, rad (imperial) Radioactivity Received by
Another Body
• Dose equivalent
– Sievert, Sv (SI)
– rem, r (imperial)

For practical purposes, 1 R (exposure) = 1 rad (absorbed dose) = 1 rem or 1000 mrem (dose equivalent).

No equivalency can be made between radioactivity and exposure or dose because energy levels, shielding, and
distance all play roles in how much radioactivity is transmitted through air to deposit in materials.

NORM Primer 11
 Typical Field Instrumentation
• These instruments count disintegrations per minute,
received through an air medium, and typically count
either -/-producing disintegrations or -producing
disintegrations.
• These instruments measure exposure in µSv/hr or
µR/hr.
• These instruments are not capable of:
– Identifying isotopes.
– Correlating between measured disintegrations per
minute and the regulation-driven radioactivity per
unit mass in specific isotope energy ranges.
– Determining true radioactivity, measured directly.

12 NORM Primer
Analytical Aspects of NORM Waste
Only under certain conditions can reliable As the shielding provided by the scale or sludge
estimates of the activity concentration of mass itself and the wall of the equipment can be
-emitting nuclides be obtained from the readings substantial, it is usually not possible to reliably
of dose rate on the outside of a waste container. convert the measured dose rates into activity per
unit mass of scale or sludge.
Usually, the radiological characterization of NORM
waste will demand nuclide-specific analysis by Source: IAEA Radiation Protection and the Management of Radioactive Waste in
the Oil & Gas Industry, Vienna, 2010, Training Course Series No. 40.
high-resolution gamma spectrometry at a qualified
laboratory. The method requires sophisticated
equipment operated by experienced analysts.

NORM Primer 13
 Common Radiation Factoids
Typical Radioactivity Levels Dosage Limits
• Average coal – 4 pCi/g • OSHA (Occupational Safety and Health
• Cat litter – 5 pCi/g Administration)-defined minor – 0.5 rem (yearly)

• Coffee grounds – 27 pCi/g • OSHA-defined worker – 5 rem (yearly)

• Granite countertop – 27 pCi/g • Astronauts – 25 rem (lifetime)

• Coal ash – 54 pCi/g • Nausea ≈ 50 rem (acute)

• Phosphate fertilizer – 123 pCi/g • 100% fatality ≈ 200 rem/hr (acute)

• Uranium ore (0.3%) – 13,500 pCi/g

• Food: see table below Typical Doses
• Average national background – 620 mrem (yearly)
Food Source 40
K pCi/g 226
Ra pCi/g – Half of this is from radon gas.
Banana 3.52 Negligible • Living next to nuclear plant for 1 yr – 1 mrem
Brazil Nut 5.60 1–7 • Sleeping next to person for 1 yr – 2 mrem
Carrot 3.40 0–0.002 • 6-hr airplane flight at altitude – 4 mrem
White Potato 3.40 0–0.0025 • 0.5-sec mammogram – 40 mrem
Beer 0.39 Negligible • Barium x-ray – 400 mrem
Red Meat 3.00 Negligible • 1 pack of cigarettes/day for 1 yr – 1300 mrem
Lima Bean 4.64 0–0.005
Drinking Water – Negligible

Radioactivity is all around us. Many everyday

items are radioactive. Would you think twice
about touching freshly ground coffee or even
carrying a packet around in your pocket?
Probably not, yet the average packet of ground
coffee likely is more radioactive than much of
the oilfield waste currently classified as NORM
waste and trucked to licensed disposal facilities.

14 NORM Primer
EPA Claims of Radioactivity Ranges
for NORM Wastes
Vague information such as this offered on the U.S. Environmental Protection Agency (EPA) Web page may provide
impetus for industry to develop a better inventory data set.

The public will focus on the "high" numbers, which may or may not be representative of Bakken numbers. Industry's
challenge is to develop better data to represent the correct status.

Radiation Level, pCi/g

Low Average High
Phosphate Fertilizer 0.5 5.7 21

Soils of the United States 0.2 – 4.2

Oil and Gas Production Produced water, pCi/L 0.1 – 9000

Wastes Pipe/tank scale <0.25 <200 >100,000

Drinking Water Treatment sludge, pCi/L 1.3 11 11,686

Treatment Wastes Treatment plant filters – 40,000 –

Wastewater Treatment Treatment sludge, pCi/L 0 2 47

Wastes Treatment plant ash 0 2 22

Bottom ash 1.6 3.5–4.6 7.7

Coal Ash
Fly ash 2 5.8 9.7

Uranium mining overburden – – Low

Uranium Mining Wastes Uranium in situ leachate evaporation pond 3 30 3000

Solids 300 – 3000

U.S. EPA, www.epa.gov/radiation/tenorm/index.html (accessed 2014).

NORM Primer 15
 It All Starts with Chemistry!

When we discu
NORM, we focu
a few elements

16 NORM Primer
uss
us on
s ….

NORM Primer 17
 Decay of 238U Results in NORM
An important decay chain is the decay of 238U
238
92 U 234
92 U • 222Rn is radioactive and has several characteristics
that magnify its health effects:
Uranium 4.5e9
years
245,500
years


–
– Radon is a gas. It can seep through soil and cracks in rock

234
91 Pa  into the air and accumulate to high concentrations.
– Radon decay emits  particles, radiation that
Protactinium 27 days


– presents the greatest hazard to lung tissue.
234
92 Th 230
90 Th – Radon’s very short half-life (3.8 days) means that it emits
Thorium 27 days 75,380
years
alpha particles at a high rate.
• 226Ra, 210Po, and 210Pb are other products of this decay chain
 that are monitored in NORM wastes
Actinium

226
88 Ra
Radium 1602 years


Actinides
Francium
Alkaline-Earth Metals
222
86 Rn Halogens
Radon 3.8 days
Metalloids
Noble Gases

218
85 At Poor Metals
Astatine 1.5
seconds
Transition Metals
218
84 Po 
214
84 Po
0.1643
210
84 Po
Polonium 3.1 minutes
seconds
138 days

– –
 

214
83 Bi 210
83 Bi 
Bismuth 20 minutes 5 days

– –
 
214
82 Pb
26.8
 210
82 Pb  206
82 Pb
Lead minutes 22.3 years Stable
– –
 
210
81 Tl 
206
81 Tl
Thallium 1.3 minutes 4.2 minutes

206
80 Hg
Mercury 8.1 minutes

18 NORM Primer
Decay of 232Th Results in NORM
• A different radioactive decay process results in 228Ra,
another isotope monitored in NORM wastes.
232
90 Th 228
92 Th • Like 226Ra, 228Ra is also radioactive and has several
Thorium 1.41e+10
years
1.9 years
characteristics that magnify its health effects:
–

– Radium, like calcium, will be carried to bones.

228
89 Ac 
– Because 228Ra is a  emitter, the radium isotope will
Actinium 6.1
minutes


– continue to bombard surrounding tissue with
228
88 Ra 224
88 Ra  radiation until it is eventually flushed out of the
body, increasing the chances of cancer.
Radium 5.7 years 3.6 days

– Bone cancer, anemia, and cataracts are some of the


documented medical issues associated with 228Ra.
Francium

220
86 Rn
Radon 55 seconds

Actinides
 Alkaline-Earth Metals
Astatine Halogens
Metalloids
216
84 Po 212
84 Po Noble Gases
Polonium 0.14
seconds
3e-07
seconds
Poor Metals
–


212
83 Bi 
Transition Metals

Bismuth 61
minutes

Pb

212
82 
214
84 Pb
Lead 10.6 hours Stable
–

208
81 Tl
Thallium 3.1 minutes

NORM Primer 19
20 NORM Primer
HANDLING AND
DISPOSAL OF
NORM WASTES

NORM Primer 21
 NORM Disposal Options
Disposal Method Description
Land Spreading Land spreading involves disposal by spreading sludge and scale on the
surface/open lands in an area where NORM was not originally present above
background levels.

Land Spreading with Dilution Land spreading with dilution involves mixing of the applied NORM thoroughly
(land farming) within the top 8-inch (20.3-cm) layer of soil using agricultural equipment in an
area where NORM was not originally present above background levels.

Nonretrieved Line (surface) Buried line pipe used at a facility could be abandoned in place after being
Pipe flushed to remove any oil or gas present.

Burial with Unrestricted Site Burial with unrestricted site use involves burial of NORM with at least
Use 15 feet (4.6 m) of cover that is level with the surrounding terrain, minimizing
erosion potential.

Commercial Oil Industry Disposal in a commercial oil industry waste facility assumes burial with other
Waste Facility oilfield wastes where NORM represents less than 7% of the total waste volume.

Commercial NORM Waste A NORM waste disposal site is designed to contain NORM for long periods, and its
Facility control may revert to a national authority for permanent monitoring and restricted
future use after closure.

Commercial Low-Level A low-level radioactive waste disposal facility is defined and licensed under
Radioactive Waste Facility national regulations with numerous protective features and restrictions.

Plugged and Abandoned Well Well abandonment operations provide an opportunity to dispose of NORM.

Well Injection Hydraulic Sludge and scale wastes could be injected or fractured into formations that are
Fracturing isolated geologically and mechanically.

Equipment Release to Smelter Smelting may be a viable option for NORM-contaminated tubulars and other
equipment.

Currently favored and widely accepted options.

22 NORM Primer
 Licensed NORM Disposal Sites
in the United States

Washington Maine

U.S. Ecology Oaks Disposal Services Vermont

Montana North Dakota New Hampshire
Minnesota
Oregon Massachusetts
Idaho New York
Wisconsin Rhode Island
South Dakota Michigan Connecticut
U.S. Ecology
Wyoming Pennsylvania
Wayne Disposal, Inc. New Jersey
Iowa
Nebraska Ohio Maryland Delaware
Indiana
Nevada Illinois West Virginia
Clean Harbors
Utah Virginia
Colorado
California Kansas Missouri Kentucky

Clean Harbors UNITED STATES Tennessee

North Carolina

Oklahoma South Carolina

Arizona Arkansas
New Mexico
Alabama Georgia
Mississippi
Lotus, LLC
Texas Chemical Waste Management
M.B. Environmental Service Louisiana

NORM Disposal Sites U.S. Ecology Florida

NORM Disposal Facilities (landfills)

Injection Wells

NORM Decontamination Facilities

NORM Primer 23
24 NORM Primer
REGULATION OF
NORM WASTES

NORM Primer 25
 States Have Primacy over
NORM Disposal Regulations
Wastes containing NORM are generally not regulated by
federal agencies:
• One exception is that the transportation of NORM-
containing wastes is subject to U.S. Department of
Transportation regulations.
• NORM management activities may be subject to
regulations promulgated by OSHA.

26 NORM Primer
Summary of Weakness of
State NORM Part N – Field
Regulations Employability
• In 1997, the Conference of Radiation Control Program • The activity thresholds suggested in Part N are largely
Directors (CRCPD), a group of state and local regulators, derived from modeling done at Argonne National
developed a set of suggested state regulations for Laboratory that attempted to correlate an activity level
control of radiation (SSRCR) as a model standard that results in predicted absorbed dose levels and
guidance for regulating NORM in an attempt to lead associated potential biological damage.
the states to uniform regulation of NORM. • Many broad assumptions need to be made to make
• This document is commonly referred to as “the CRCPD these correlations.
Part N Template” and attempts to answer the following • Measurement of total radioactivity of specific isotopes
questions: (and associated energy levels) is complex, requiring
– Do I have TENORM? time, advanced analytical equipment, and detailed
laboratory methodologies.
– How do I dispose of TENORM waste?
– What radiation measurements are required to
comply with Part N?
• Most states that regulate NORM do so on the basis of a
threshold radioactivity level (emission) – pCi/g of 226Ra
and 228Ra above background
• Many of these states use the 5-pCi/g threshold
recommended by Part N (see Section 7, ¶ b.ii.)
• No specific measurement methodology is prescribed
within Part N (see Section 6):
– The Energy & Environmental Research Center (EERC)
has discussed measurement methodology with
many radiation instrument manufacturers. None had
field-based instruments that could measure pCi/g of
specific Ra isotopes.

NORM Primer 27
 15 States with NORM-Specific
Regulations

270
5
5 WA
50
MT ND ME

5 5
VT
OR NH MA
MN WI
ID SD NY
WY CT RI
MI

5
IA PA
NV NE NJ
UT IL IN DE
OH
CA CO MD
KS MO wv VA
KY
NC
TN
AZ OK

NM AR
AL
GA SC
5
MS
5
30
TX LA

5
FL

5
HI

30 5
AK
NORM-Specific Regulation States

WY, KY, and PA regulate the presence

of radium in produced water that is
discharged into surface water.

The numbers in each state are grossly indicative of that state’s threshold (in pCi/gr 226Ra and/or 228Ra) for exemption
from state NORM disposal rules. This is an extreme simplification. Refer to state-specific regulations for more
accurate detail.

28 NORM Primer
15 States with NORM-Specific Regulations

Alabama Regulations
Although Alabama does not have NORM-specific regulations, it does define thresholds that require a radioactive license
on its Department of Public Health Web site (www.adph.org/radiation/Default.asp?id=1907).
To determine if the NORM concentration is such that it will require a radioactive material license, Alabama has adopted
two thresholds:
• >50 µR/hr (background included) at contact with item. This threshold is only to be used for discreet items
such as pipes or tanks and the TENORM-contaminated scale or sludge contained in these pipes or tanks.
• >5 pCi/g of combined 226Ra and 228Ra.

Arkansas Regulations
In accordance with Arkansas State Board of Health Rules and Regulations for Control of Sources of Ionizing Radiation, RH-
1210g, exceptions to regulated disposal are provided as follows:
226
Ra or 228Ra in soil averaged over any 100 m² shall not exceed the background level by more than:
a) 5 pCi/g, averaged over the first 15 cm of soil below the surface.
b) 15 pCi/g, averaged over 15-cm-thick layers of soil more than 15 cm below the surface.

Georgia Regulations
In accordance with Georgia Rule 391-3-17-.08, exceptions to regulated disposal are provided as follows:

1 (i) 30 pCi/g of 226Ra or 228Ra in soil, averaged over any 100 m² and averaged over the first 15 cm of soil below
the surface, if Rn emanation rate is <20 pCi/m²/s.
(ii) 30 pCi/g of 226Ra or 228Ra in media other than soil, if Rn emanation rate is <20 pCi/m²/s.

2 (i) 5 pCi/g of 226Ra or 228Ra in soil, averaged over any 100 m² and averaged over the first 15 cm of soil below
the surface, if Rn emanation rate is >20 pCi/m²/s.
(ii) 5 pCi/g of of 226Ra or 228Ra in media other than soil, if Rn emanation rate is >20 pCi/m²/s.

3 (i) 150 pCi/g of any other NORM radionuclide in soil, averaged over any 100 m² and averaged over the first
15 cm of soil below the surface, if these concentrations are not exceeded at any time.
(ii) 150 pCi/g of any other NORM radionuclide in media other than soil, if these concentrations are not
exceeded at any time.

Kentucky Regulations
In accordance with Kentucky Administration Regulations Title 401, Chapter 10:031, the Division of Oil and Gas does not
have specific NORM regulations; however, the Department for Environmental Protection, Division of Water, regulates the
presence of radium in produced water that is discharged into surface water (<5 pCi/L).

NORM Primer 29
 Louisiana Regulations
In accordance with Louisiana Administrative Code Title 33, Part XV, Chapter 14, §1404 and §1412, exceptions to regulated
disposal are provided as follows:
NORM waste:
• <5 pCi/g of 226
Ra or 228
Ra, above background.
• <150 pCi/g of any other radionuclide.
Contaminated equipment:
• Exposure level <50 mR/hr at any accessible point.
Land:
• <5 pCi/g of 226Ra or 228Ra above background, averaged over the first 15 cm.
• <15 pCi/g above background over everything deeper.
• <30 pCi/g of 226Ra or 228Ra, averaged over 15-cm depths, provided the total effective dose equivalent does
not exceed 0.1 rem (1 mSv) in a year.

Maine Regulations
In accordance with Maine Department of Health and Human Services Rule 10-144, Chapter 220, Part N, exceptions to
regulated disposal are provided as follows:
• <5 pCi/g of 226Ra and 228Ra, excluding natural background.
• Distribution and disposal of fertilizers are exempt from these requirements.
• Other TENORM is exempt when the agency makes a determination that a maximally exposed individual will not
receive a dose of >0.1 rem in 1 year from all exposure pathways.

Michigan Regulations
In accordance with the Michigan Department of Environmental Quality’s Ionizing Radiation Rules 123(3)e, 237(1), 237(2),
237(3), 253, and 272, exceptions to regulated disposal are provided as follows:
• Materials containing 226Ra <50 pCi/g, averaged over any single shipment.
• Any NORM wastes containing 226Ra at any concentration generated during plugging and abandonment
operations, disposed of downhole.

Minnesota Regulations
In accordance with Minnesota Administrative Rules (MAR) Chapter 4731, exceptions to regulated disposal are provided as
follows:
• Material activity concentrations and consignment activity levels <270 pCi/g for both 226Ra and 228Ra (MAR
Chapter 4731.0422, Subpart 3).
• Material activity concentrations consignment activity levels for other radionuclide mixtures, broken down by
radiation emission types (α, β, ) <270 pCi/g (MAR Chapter 4731.0423, Subpart 6).

30 NORM Primer
Mississippi Regulations
In accordance with Title 15, Part 21, Subpart 78, Chapter 1, Subchapter 11, Rule 1.11.4 of Mississippi regulations, exceptions
to regulated disposal are provided as follows:
• <5 pCi/g of 226
Ra or 228
Ra above background.
• <30 pCi/g of 226
Ra or 228
Ra, averaged over any 100 m², if the radon emanation rate <20 pCi/m²/s.
• <150 pCi/g of any other radionuclide, if these concentrations are not exceeded at any time.
• Equipment <25 mR/hr above background radiation at any accessible point.

Exempt products or materials:

1. Phosphate and potash fertilizer
2. Phosphogypsum for agricultural uses

Produced waters from crude oil and natural gas production are exempt from the requirements of these regulations if the
produced waters are reinjected in an approved well.

New Jersey Regulations

In accordance with New Jersey Administrative Code Title 7, Chapter 28, Subchapter 4.3(a)5, exceptions to regulated
disposal are provided as follows:
• <5 pCi/g of 226Ra and 228Ra above background.

New Mexico Regulations

In accordance with New Mexico Administrative Code Title 20, Chapter 3, Part 1, Subpart 14, exceptions to regulated
disposal are provided as follows:
In soils, in 15-cm layers averaged over 100 m²:
• <30 pCi/g of 226Ra above background.
• <150 pCi/g of any other NORM radionuclide above background.

Exempt products/materials:
• Natural gas and natural gas products as fuels.
• Crude oil and crude oil products as fuels .
• Removable scale from gas processing and dry gas distribution is exempt if <150 pCi/g of 210Pb in scale.
• Produced water is exempt if reinjected into a permitted well or stored in a permitted impoundment.

Other exemptions:
• Exposure readings <50 mR/hr, including background radiation levels, at any accessible point.

Surface contamination exemptions:

• <10 dpm/cm² (disintegrations per minute per square centimeter).

NORM Primer 31
 Ohio Regulations
In accordance with Ohio Administrative Code Chapter 3701-39, §02.1, exceptions to regulated disposal are provided as follows:
Soil or nonsoil media containing 226Ra or 228Ra with Rn emanation rate of <20 pCi/m²/s
• <27 pCi/g , if the concentration of 226Ra or 228Ra, averaged over any 100 m² and averaged over the first 15 cm
below the surface.
Soil or nonsoil media containing 226Ra or 228Ra with Rn emanation rate of >20 pCi/m²/s
• <5 pCi/g , if the concentration of 226Ra or 228Ra, averaged over any 100 m² and averaged over the first 15 cm
below the surface.
Soil or nonsoil media containing other radionuclides
• <135 pCi/g , if the concentration of radionuclides, averaged over any 100 m² and averaged over the first 15 cm
below the surface.
Materials or equipment contaminated with scale or residue
• Exposure level <25 mR/hr above background at any accessible point

Oregon Regulations
In accordance with Oregon Administrative Rule 333-117-0040, exceptions to regulated disposal are provided as follows:
• <5 pCi/g of Ra.
• <150 pCi/g of any other radionuclide, if these concentrations are not exceeded at any time.
Exempt products:
• Brazil nuts
• Phosphate and potash fertilizer
• Phosphogypsum for agricultural uses
• Natural gas and natural gas products as a fuel

Pennsylvania Regulations
In accordance with Pennsylvania Code Title 25, Chapter 95, 40 Pa.B.4835, the Bureau of Oil and Gas does not have specific
NORM regulations; however, the Department for Environmental Quality regulates the amount of radium produced by oil
and gas operations and discharged into surface water.

South Carolina Regulations

In accordance with South Carolina Code of Regulations 61-63, Title A, Part IX, exceptions to regulated disposal are
provided as follows:
Activity Concentration
• <30 pCi/g of 226Ra or 228Ra in soil or nonsoil media, averaged over any 100 m² and averaged over the first 15 cm
below the surface, provided the radon emanation rate is <20 pCi/m²/s.

32 NORM Primer
South Carolina Regulations (continued)
• <5 pCi/g of 226Ra or 228Ra in soil or nonsoil media, averaged over any 100 m² and averaged over the first 15 cm
below the surface, if the radon emanation rate is >20 pCi/m²/s.
• <150 pCi/g of any other NORM radionuclide in soil or nonsoil media, averaged over any 100 m² and averaged
over the first 15 cm below the surface.

Exempt Materials and Equipment

• Radiation exposure level <50 mR/hr at any accessible point, including the background radiation level.

Surface Contamination
• Average <5000 dpm per 100 cm² over the entire measured surface.
• <15,000 dpm per 100 cm² in an area <100 cm², notwithstanding the aforementioned limit.
• Removable contamination <10 dpm/cm².

Texas Regulations
In accordance with the Texas Commission on Environmental Quality Radioactive Materials Division Document RG-486,
exceptions to regulated disposal are provided as follows:
Unrestricted Use
• A site meets the unrestricted use requirement if the residual radioactivity distinguishable from background radiation:
– Results in a TEDE (total effective dose equivalent) of <25 mrem/yr (30 Texas Administrative Code [TAC] 336.603).
– Is <5 pCi/g of 226Ra or 228Ra, averaged over any 100 cm² and the first 15 cm of soil below the surface.
– Is <15 pCi/g of 226Ra or 228Ra, averaged over any 100 cm² and each subsequent 15 cm layer of soil.

Surface Contamination Exemptions (30 TAC 336.364, Appendix G)

Radionuclide Average Maximum Removable

nat
U, 235U, 238U, and Associated Decay Products Except 226Ra, 230Th, 5000 dpm α 15,000 dpm α 1000 dpm α
227
Ac, and 231Pa per 100 cm² per 100 cm² per 100 cm²
Transuranics, 223Ra, 224Ra, 226Ra, 228Ra, natTh, 228Th, 230Th, 232Th, 232U, 1000 dpm 3000 dpm 200 dpm
Pa, 227Ac, 90Sr, 125I, 126I, 129I, 131I, and 133I
231
per 100 cm² per 100 cm² per 100 cm²
β- emitters (radionuclides with decay modes other than α emission 5000 dpm β- 15,000 dpm β- 1000 dpm β-
or spontaneous fission) except 90Sr and others noted above per 100 cm² per 100 cm² per 100 cm²

Disposal Exemptions (25 TAC 289.259[d])

• <30 pCi/g of Ra or 228Ra if the radon emanation rate is <20 pCi/m²/s.
226

• <5 pCi/g of 226Ra or 228Ra if the radon emanation rate is >20 pCi/m²/s.
• <150 pCi/g of any other NORM radionuclide.
226
Ra and 228Ra are considered separately, so both isotopes can be up to the limit (30 or 5 pCi/g) and still be exempt.
Texas does not allow dilution for reduction of the radioactive concentration so that the waste classification is lowered or
disposal requirements lessened (30 TAC 336.229).

NORM Primer 33
 Texas Regulations (continued)
Burial
• May dispose of oil and gas NORM waste by burial at the same site where the oil and gas NORM waste was generated
provided that, prior to burial, it has been treated or processed to <30 pCi/g 226Ra and 228Ra or <150 pCi/g of any other
NORM radionuclide.
Landfarming
• May dispose of oil and gas NORM waste at the same site where the oil and gas NORM waste was generated by applying it
to and mixing it with the land surface, provided that after such application radioactivity <30 pCi/g 226Ra and 228Ra or
<150 pCi/g of any other radionuclide.
Injection
• Injection by a licensed operator of oil and gas NORM waste that meets exemption criteria is authorized.
Equipment/Material Exemptions
• Radiation exposure level, including the background radiation level, <50 mR/hr at any accessible point (25 TAC 289.259[d][3]).
• Natural gas, natural gas products, crude oil, and crude oil products containing NORM are exempt (25 TAC 289.259[d][7]).
• Produced waters from oil and gas production are exempt if the produced waters are reinjected into an approved well (25
TAC 289.259[d][8]).
Product Exemptions
• Phosphate and potash fertilizer (25 TAC 289.259[d][6]).
• Phosphogypsum for agricultural uses (25 TAC 289.259[d][6]).
• Building construction materials, if they contain unconcentrated NORM (25 TAC 289.259[d][6]).
• Industrial processing, sandblasting, metal casings, if they contain unconcentrated NORM.
• By-products from fossil fuel combustion (bottom ash, fly ash, and by-products of flue gas emission control).

West Virginia Regulations

In accordance with the West Virginia Code, exceptions to regulated disposal are provided as follows:
Exempt with respect to any combination of 226Ra and 228Ra if:
• <5 pCi/g excluding natural background.
Shall not transfer or release for unrestricted use:
• Equipment contaminated with TENORM with a surface gamma radiation level >100 mrem/hr including natural background.
• Land where the concentration of 226Ra or 228Ra in soil averaged over any 100 m² exceeds the background level by more
than 5 pCi/g averaged over any 15 cm below the surface.

Wyoming Regulations
In accordance with Wyoming Department for Environmental Quality Water Quality Division regulations, the Oil and Gas
Conservation Commission does not have specific NORM regulations; however, the Department for Environmental Quality
Water Quality Division regulates the presence of radium in produced water that is discharged into surface water.

34 NORM Primer
 CONCLUSIONS
AND
RECOMMENDATIONS

NORM Primer 35
 The Current Regulatory Predicament
• Adequate characterization of the radionuclide – Inadequate information exists on NORM-
concentration has been a major limitation of most contaminated inventories because of this
NORM risk assessments conducted to date. measurement problem.
– To determine hazards from radiation, one
must know not only the activity level of the • Most state regulations focus on activity level alone.
material, but also the type of radiation The regulations are written to set thresholds on the
emitted (, , ) and the total amount of activity level of specific isotopes.
energy that is deposited by the radiation in
tissue or organs. • Therefore, regulations are difficult or impossible
to enforce or responsibly employ.
– No field-deployable instrument is currently capable
of measuring isotope activity concentration directly
and accurately.

A Few EERC Opinions

• Regulations suggested by CRCPD Part N are • North Dakota should continue its efforts to enable
difficult or impossible to enforce by regulators or and actively promote carefully designed in-state
employ by responsible industry. Therefore, North solutions for NORM waste disposal:
Dakota should consider a departure from the Part – Injection wells
N template to permit regulators and the oil and gas
industry to responsibly and efficiently determine – NORM waste-receiving landfills
disposition of NORM wastes.
• All involved parties should redouble efforts to
• To determine appropriate thresholds (units and educate the public and each other about NORM
magnitudes) in regulations, industry and the science. Radiation can be used as an emotional
North Dakota Department of Health should work word if the science of radiation is not conveyed
together to determine what measurements can accurately and simply.
be made routinely in the field and what threshold
values of those measurements pose a true public
health hazard.

36 NORM Primer
For More Information, Contact
John A. Harju
Associate Director for Research
(701) 777-5157
jharju@undeerc.org

Jay C. Almlie
Senior Research Manager
(701) 777-5260
jalmlie@undeerc.org

Energy & Environmental Research Center

15 North 23rd Street, Stop 9018
Grand Forks, ND 58202-9018

www.undeerc.org

NORM Primer 37
 EERC
Energy & Environmental Research Center ®

Putting Research into Practice

NORM Primer

© 2014 University of North Dakota Energy & Environmental Research Center