TENORM Waste Management

Transcription

1 TENORM Waste Management Wyoming Solid Waste & Recycling Association Annual Conference August 2015

2 Presentation Outline Background Operations and Infrastructure Considerations Regulatory Update Campbell County SOP Summary 2

3 BACKGROUND 3

4 TENORM Waste What is NORM? Naturally Occurring Radioactive Material The geologic formations that contain oil and gas deposits also contain naturally-occurring radionuclides, which are referred to as "NORM What is TENORM? The oil and gas extraction process concentrates the naturally occurring radionuclides and exposes them to the surface environment and human contact (technically enhanced NORM TENORM ) Source: US EPA: 4

5 Oil Price Changes

6 Major Drilling Areas The seven regions shown accounted for 95% of domestic oil production growth and all domestic natural gas production growth during Source: U.S. Energy Information Administration 6

7

8 Fracking

9 McKenzie County Population Population Growth Year

10 A Changing Population

11 Site Development August 31, 2009

12 September 7, 2011

13 August 15, 2013

14 September 24, 2014

15 Types of Issues Faced Infrastructure Are the existing roads, scale house, and other sufficient for increased traffic? Will construction of the next cell need to be expedited? Design and Permitting Will the types of waste accepted require a change to the landfill permit or a change to the design of the landfill liner system? Operations Will additional staff and equipment be needed to accept additional waste? Testing Is there a need for additional testing, or new waste screening procedures? Financial Planning How should the additional operating and capital expenses be paid for? What happens if the market, and therefore additional tonnage, declines? 15

16 Types of Oil Field Waste Addressed Municipal Solid Waste Increased residential waste from temporary and permanent population increases due to nearby drilling activity Waste generated from construction activity (homes, businesses, drill sites) Drilling Waste Class I Industrial Waste (TX), Special Waste (ND) Waste generated directly from drilling activity (oil contaminated soils, drill cuttings, etc.) Hazardous Waste and Radioactive Waste Naturally occurring radioactive material Other hazardous wastes 16

17 MSW Oil Field Waste Wood pallets Empty bags Plastic pipe Cardboard boxes Other empty containers Worker s personal waste (bottles, bags, food waste, etc.) Not oil field cuttings, drilling water, spills, etc. 17

18 Landfill Rates McKenzie County Landfill MSW = $35 per ton Oil Field (MSW) = $165 per ton Dickinson Landfill MSW = $40 per ton Oil Field (MSW) = $185 per ton Williston Landfill MSW = $40 per ton Oil Field (MSW) = $165 per ton 18

19 Oil Field Waste

20 Oil Field Waste

21 Rejected Oil Field Waste 21

22 Rejected Filter Socks Source: New York Times 22

23 OPERATIONS AND INFRASTRUCTURE CONSIDERATIONS 23

24 Staffing and Equipment Difficult to hire and retain skilled staff because of competitive labor market New equipment may be needed to efficiently manage and compact waste New Testing and Screening Procedures Industrial Waste Plan may need to be updated Additional screening and testing Analytical testing In some cases, field radiation screening 24

25 How to Check for TENORM 25

26 How to Check for TENORM Drive-Through Radiation Detector 26

27 REGULATORY UPDATE 27

28 WDEQ Guideline #24 NORM Management in Wyoming Any waste material exceeding these thresholds is subject to controls and guidance by SHWD Greater than background levels Or, greater than 8 picocuries per gram And/or, decommissioned equipment from crude oil And/or, gas operations exceeding 50 microroentgens per hour emanation rate

29 WDEQ Guideline #24 Some NORM waste disposal is allowed: Greater than background but less then 30 pci/g, then up to 20 cubic yards may be disposed per 90 day period Greater than 30 pci/g and 50 pci/g, then up to 10 cubic yards may be disposed per 90 day period

30 Oil Field Waste Management in Wyoming Wyoming Oil and Gas Commission have regulatory jurisdiction of drilling waste as long as it stays on the drilling site. Not as much of an issue with TENORM in Wyoming compared to North Dakota, which is likely because of one or two things: The geological formations are different. The material used in the fracking process is different.

31 North Dakota Special Waste Special waste means solid waste that has unique handling, transportation, or disposal requirements to ensure protection of the public health, safety, and welfare and the environment. Drill Cuttings Soils Impacted By Spills Other Similar Waste Not Hazardous Waste 31

32 North Dakota Special Waste Huge increase in amount of Special Waste 2001: 9,000 tons in 3 Special Waste Landfills 2013: 1,780,000 tons in 10 Special Waste Landfills Source: North Dakota Department of Health 32

33 North Dakota Proposed Rule Change Provides a means to track TENORM waste from generation to disposal, creating accountability of the generator, transporter and disposal facility. Provides a means for generators to dispose of TENORM wastes less than 50 picocurries/gram at approved North Dakota special waste landfills. CONCERN: Lack of enforcement. CONCERN: 25,000 tons per year limit 33

34 South Dakota and Montana South Dakota Maximum allowable at MSW landfills is 5 picocurries/gram above background No special waste landfills Montana Maximum of 15 to 30 picocuries/gram depending on type of leachate collection and liner system 34

35 CAMPBELL COUNTY SOP 35

36 Standard Operating Procedure Purpose Definitions Equipment and Materials Procedures Documentation and Quality Assurance Health and Safety References 36

37 Screening Procedures 37

38 Is the customer hauling oil field refuse? Yes No Does the hauler have a Profile Analysis for the load, indicating that all material is below background radiation levels? No further NORM testing is required. Yes No 38

39 Yes No Is the load homogeneous? (e.g. petroleum contaminated soils) Screen the waste with Geiger counter. Is the load below acceptable radiation levels according to the Geiger counter test? Yes No Yes No Accept the load. Turn away the load. 39

40 Inspect the load carefully. Does the load match the material description of the profile analysis?** Yes No Accept the load. Screen the waste with Geiger counter. 40

41 Summary Oil and gas drilling waste in Wyoming does not appear to present the same TENORM challenges that North Dakota waste does North Dakota is proposing to increase allowable TENORM concentration to 50 picocurries/gram, and a tracking method from generation to final disposal It is good practice to have a screening program in place 41

42 Questions? Matt Evans, P.E. Tel: