Best Practices for Safely and Economically Disposing Radioactive Materials

Transcription

1 Best Practices for Safely and Economically Disposing Radioactive Materials Case Study of NORM and TENORM Issues in Kentucky March 29, 2017 Larry Taylor Kentucky Department for Environmental Protection

2 Contents Oil and Gas Workgroup Challenges and Goals Available Technology and Disposal Options Development of TENORM and NORM Management for Kentucky 2

3 Culminating Event 3

4 Kentucky Oil and Gas Workgroup Sets the framework and context for these issues Convened due to illegal disposal Charged with examining our processes and evaluating how other states manage oil and gas related NORM and TENORM Make recommendations for modernizing our process for NORM and TENORM generated within Kentucky. 4

5 Statutory Import Prohibition KRS (3): Naturally-occurring radioactive material (NORM) as defined in KRS (8) shall be the exclusive regulatory responsibility of the states, except that no person shall import naturally occurring radioactive material (NORM) from outside the region for disposal in Kentucky, or dispose of such imported material in Kentucky, if the imports or disposal are inconsistent with polices of the commission. 5

6 Challenges and Goals Challenges: Uncertainty Liability Cost Protectiveness Goals: Clear, predictable, cost-effective and protective strategies 6

7 Radium in Solids and Produced Water Radium levels vary depending on: Geological formation Production process Geographical location 7

8 Available Technology and Disposal Options for TENORM Management Water treatment plant\lime softening Encapsulation and solidification of solids Onsite disposal Pits Wells Land spreading Landfill Solid Waste (nonhazardous) and RCRA Low-Level Radioactive Waste 8

9 Illustration of Disposal Alternatives Source: API and USGS 9

10 Waste Streams with NORM\TENORM Drill Cuttings and muds, including oil-based muds Equipment Tubular Goods/Pipe Scale Filters Produced and Flowback Water Sludge and Tank Bottoms 10

11 Kentucky Working Approach Define the terms in statute Direct outreach to other states Defines science-based thresholds for management of waste o Produced water disposed in UIC wells; waste <5 pci/g; drill cuttings; would all be exempt from regulation as TENORM. o On-site management of drill cuttings in pits with proper reclamation guidelines. Managed as special waste. o TENORM (scale, tubulars, sludge, etc) may be disposed in a well during plugging and abandonment. 11

12 Thresholds (Continued) Landfills: > 5 pci/g to 50 pci/g in contained (nonhazardous) landfill. > 50 pci/g up to an authorized upper limit in a landfill registered with the CHFS with enhanced personnel dosimetry and enhanced cap design > authorized upper limit to a Low Level Radioactive Waste facility 12

13 Path Forward Draft regulatory amendments EEC: DOW, DWM, DNR\Division of Oil and Gas CHFS\DPH Statutory change in definition (filed 2/16/17, passed March 15, 2017) Report to Legislature was completed in December Resolve remaining issues Finalize Work Group recommendations 13

14 Statutory Change OLD: (8) "Naturally-occurring radioactive material" (NORM) means naturally occurring materials not regulated under the Atomic Energy Act of 1954, as amended, whose radionuclide concentrations have been increased by or as a result of human practices. Naturally occurring radioactive material does not include the natural radioactivity of rocks or soils, or background radiation, but instead refers to materials whose radioactivity is technologically enhanced by controllable practices (or by past human practices); NEW: (8) "Naturally-occurring radioactive material" (NORM) means any of the primordial radionuclides or radioactivity present in soils, rocks, and materials, that are not concentrated or disturbed as a result of human (13) "Technologically-enhanced naturally-occurring radioactive material" or "TENORM" means: (a) Naturally occurring radioactive material with a radionuclide concentration that has been increased by human activities above levels encountered in the natural state; or (b) Naturally occurring radioactive material made more accessible by human activity. TENORM does not include the natural radioactivity of rocks or soils or source material, byproduct material, or special nuclear material as defined in 42 U.S.C. secs et seq. and relevant federal regulations implemented by the Nuclear Regulatory Commission; 14

15 Conclusions Essential to develop an approach that is: Economical Protective of exposure limits for workers and the public Provides for better characterization and knowledge of the waste Reduces liability and necessity for future corrective action Clear and predictable and allows for both industries to operate and know what to expect 15

16 Contact Information Larry C. Taylor Environmental Scientist Consultant Kentucky Department for Environmental Protection Commissioner s Office 300 Sower Boulevard Frankfort, KY Phone: (502) Fax: (502) LarryC.Tayor@ky.gov 16