Assessment of TENORM Disposal in North

Dakota Industrial Waste and Special

Waste Landfills

C.B. Harto, K.P. Smith, S. Kamboj, and J.J. Quinn

Environmental Science Division
Argonne National Laboratory

Public Meeting Presentation

Williston, Jan. 20 / Bismarck, Jan. 21 / Fargo, Jan. 22
Argonne National Laboratory Was Established in 1946
Operated
Operated by
by UChicago
UChicago Argonne,
Argonne, LLC
LLC for
for the
the U.S.
U.S. Department
Department of
of Energy
Energy

Multidisciplinary
Multidisciplinary science
science and
and engineering
engineering research
research center
center

Pioneering
Pioneering research
research to
to help
help pave
pave the
the way
way to
to aa secure
secure
nation
nation with
with aa plentiful
plentiful supply
supply of
of safe,
safe, sustainable
sustainable energy;
energy; aa
healthy
healthy environment;
environment; andand aa competitive
competitive economy.
economy.

CORE
CORE CAPABILITIES:
CAPABILITIES:

National
Energy Environment Security

IAEA ENVIRONET Annual Meeting, 2-4 November 2011

2
Argonne’s Environmental Science Division Conducts
Research on a Broad Array of Energy and Environmental
Decision Making
Research Mission

 Conduct basic and applied research on how

Oil & Gas Development
natural systems behave in response to Energy Transmission

change, and how to mitigate adverse

change.

 Conduct science-based analyses of

Nuclear Power
emerging environmental issues, with a focus Renewable Energy
on energy development.

 Support formulation of policies and

regulations ensuring safe, environmentally
responsible, and economically sustainable
energy development. Hydropower

Offshore
Energy
North Dakota Public Meetings, January 2015
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Argonne Has Developed Computer Codes to Assess
Radiological Risk
 The RESRAD code was developed with funding from the U.S. Department of
Energy and U.S. Nuclear Regulatory Commission.
 It is used to develop site-specific guidelines for managing residual radioactive
materials:
– Estimate radiation doses and cancer risks for future site users,
– Evaluate the effectiveness of various disposal and remediation actions in terms of
limiting future radiation exposures,
– Evaluate uncertainty associated with key
site and/or waste parameters, and
– Establish appropriate cleanup criteria from
a risk-based perspective.

 Argonne also has developed the TSD-DOSE

code to evaluate risk from specific
treatment, storage, and disposal (TSD)
activities.

RESRAD = RESidual RADioactivity

North Dakota Public Meetings, January 2015
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Argonne Has Studied the Management and Disposal of
Petroleum Industry TENORM Wastes for Decades
 Initial work funded by the U.S. Department of Energy, starting in early 1990s
 Additional analyses conducted for other states and national and international
oil companies
 Studies have covered:
– TENORM overview
– Dose and risk assessments
• Equipment decontamination and smelting
• Landspreading disposal
• Underground injection
• Salt cavern disposal
• Landfill disposal
– Cost assessments
– Site characterization

 These studies have supported the development of TENORM policies and

regulations, as well as company-specific TENORM management strategies.

North Dakota Public Meetings, January 2015

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Study Objective
Support the North Dakota Department of Health’s (NDDH) evaluation of issues
associated with the management and disposal of TENORM.
The study was structured with two separate parts.
The objectives were to evaluate potential doses to workers and the general public
resulting from:

1. Disposal of TENORM wastes in permitted Industrial Waste and Special Waste

Landfills in North Dakota.
 Transportation of TENORM to landfills
 Landfill operations
 Future use of the landfill property

2. Oilfield activities involving TENORM

 Worker exposures from wellsite operations
 Accidental public exposures to mismanaged filter socks and proppants

North Dakota Public Meetings, January 2015

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Naturally Occurring Radioactive Material (NORM) is
Present in our Environment
 Radionuclides occur naturally in air, water, and soil.
 Background radiation comes from
– Cosmic radiation
– Terrestrial radiation
– Internal radiation
 Background radiation levels vary by geographic location, depending upon local
elevation and geology.
 Radionuclides also occur in food we eat, and in materials commonly present in our
homes, offices, and schools.

Radioactivity in Foods Radioactivity in Consumer Products

A number of food items naturally contain Many items in and around our homes,
potassium-40 and radium-226: offices, and schools contain radionuclides:
 Bananas  Red meat  Smoke detectors  Ceramics
 Carrots  Brazil nuts  Compact  Glassware
 Potatoes  Beer fluorescent lights  Fertilizers
 Lima beans  Drinking water  Watches and  Granite
clocks countertops

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 What is TENORM?
 Some petroleum industry waste
streams contain radioactive
materials.
 These materials come from
naturally occurring radionuclides
present in underground rock
formations from which oil and
gas are produced.
 In some instances, these wastes
contain radiation above
background concentrations.
 These materials are referred to
as technologically enhanced
naturally occurring radioactive
materials or TENORM. Origins of TENORM and Where It May Accumulate
Source: International Assoc. of Oil & Gas Producers, Report No. 412 (2008)

North Dakota Public Meetings, January 2015

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Radionuclides of Concern in Petroleum Industry
TENORM
Th-232
U-238
Th-228
U-234
 14 x 109 yrs 
 4.5 x 109 yrs 
1.2 mins
 240,000 yrs
6.1 hrs
 1.9 yrs Thorium-232
Uranium-238
Pa-234 Ac-228 Decay Series
Decay Series
 Th-230 
Ra-224
24 days
5.8 yrs
Th-234  77,000 yrs
Ra-228  3.6 days

Ra-
226 Rn-220

 1,600 yrs
Po-212
 55 sec

Rn-222 
Po-214 Po-210
Po-216 61 mins 
 3.8 days   300 nsec
20 mins 5 days
Bi-212
 160  0.15 sec
Po-218
sec
Bi-214 Bi-210  Pb-208 (stable)
 3.1 mins 11 hrs
   140 days  61 mins
27 mins 22 yrs Pb-212 
3.1 mins
Pb-214
Pb-210 Pb-206
Tl-208
(stable)

North Dakota Public Meetings, January 2015

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Radiation Terminology

 Radiation is a type of energy that travels in

waves or particles.
 Radioactivity is measured in units of pCi/g.
 When a person is exposed to radiation, the
energy penetrates the body.
 Exposure is measured in dose units of mrem/yr.

North Dakota Public Meetings, January 2015

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Typical Radiation Exposure Levels for Common Activities (Source:
NRC 2014)

The ICRP and NCRP recommend

an annual dose limit of 100 mrem/yr
from non-background sources of
radiation.

ICRP = International Commission on Radiological Protection

NCRP = National Council on Radiation Protection and Measurements
North Dakota Public Meetings, January 2015
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TENORM Waste Streams from Oil and Gas
Development in North Dakota
 Produced Water
– Formation water that is produced along with hydrocarbons. Radionuclides that are
mobilized in formation water are brought to the surface in this waste stream.
 Scale
– Hard and relatively insoluble deposits that accumulate inside production and processing
equipment and on solid debris (e.g., sand grains) that comes in contact with produced
water (typically BaSO4 or SrSO4). Radionuclides can co-precipitate with the sulfate scales.
 Sludge and Filter Cake
– Solid material including mud, sand, scale, and rust that settles or is filtered out of
produced water. It is found in vessels used to store or manage produced water and in
filter socks.
 Filter Socks
– Disposable filters used for filtering produced water accumulate sludge and filter cake
over time which may contain radionuclides
 Synthetic Proppants
– Some imported synthetic proppants can contain low concentrations of radionuclides
 Contaminated Soils and Equipment
North Dakota Public Meetings, January 2015
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Radionuclide Concentrations Based on Available
Data for North Dakota TENORM

The average and

maximum values for
each radionuclide were
used to assess potential
doses associated with
oilfield operations.

The analysis of doses

associated with landfill
disposal was not based
on these data.

Based on data provided by the NDDH. Columns represent average radionuclide

concentrations, error bars represent minimum and maximum value, white numbers
represent the total number of samples represented

North Dakota Public Meetings, January 2015

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Pathway Analysis Is Used to Assess Radiological Dose and Risk
Environmental Exposure Dose or
Source Pathway Pathway Cancer Risk
On-Site External
Direct Exposure Radiation

On-Site Air Dust/

Concentration H-3

Radon

Inhalation
Plant Foods Effective
Dose
Equivalent/
Excess
On-Site Water Cancer
Contamination Risk
to an
Exposed
Livestock Meat Individual

Milk

Ingestion
Aquatic
Foods

On-Site Soil
Contamination

Doses are converted to carcinogenic risk using risk factors identified by the ICRP.
North Dakota Public Meetings, January 2015
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Several Different Pathway Analysis Codes Were
Used to Support the Radiological Dose Assessments

 RESRAD
– Future use of the property following landfill closure

 RESRAD Build
– Oilfield operations
– Mismanaged filter socks and proppants

 RADTRAN
– Transportation of TENORM to landfills

 TSD-DOSE
– Landfill operations

 RESRAD Offsite
– Used to evaluate groundwater transportation of TENORM, including decay

North Dakota Public Meetings, January 2015

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Hydrologic Modeling Was Conducted to Support
Dose Assessments for Some Exposure Scenarios
Hydrologic modeling evaluated the possible movement of radionuclides:
 Through the landfill into subsurface groundwater and
 Through the subsurface to a drinking water well

Several landfill performance scenarios were modeled using three models:

 HELP (U.S. Environmental Protection Agency)
– Models infiltration and percolation through landfill materials
 MODFLOW (U.S. Geological Survey)
– Models groundwater flow
 MT3DMS (U.S. Army Corps of Engineers)
– Models contaminant fate and transport processes (e.g., from landfill to water well)

The human dose assessments related to exposure to contaminated

leachate and groundwater were based on the worst-case scenarios
(e.g., failure of both the landfill cap and liner systems).

North Dakota Public Meetings, January 2015

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Different Modeling Methodologies Were Used to
Evaluate Various Scenarios
Well Site Operations and Accidental Public Exposures
 Dose rates are based on average and maximum radionuclide concentrations as
presented in available waste characterization data provided by NDDH.
 The proposed new TENORM disposal rule does not address any of these oilfield
operation scenarios.

Landfill Operation and Future Use of Landfill Property

 The analysis calculated the maximum concentration of radionuclides that could be
disposed of in the landfill without resulting in doses greater than 100 mrem/yr for
any receptor.
 Dose rates for transportation-related exposures were based on the maximum
concentrations calculated for the landfill disposal option.

North Dakota Public Meetings, January 2015

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Well Site Operations Scenarios
Scenario Waste Stream Assumptions
Well pad workers  
Mixing hydraulic fracturing fluid Proppant Exposure time: 2,000 hrs/yr
Worker wears PPE
Produced water filtration Filter cake, filter socks Exposure time: 250 hrs/yr
Equipment cleaning workers  
Pipe cleaning Scale Exposure time: 2,000 hrs/yr
Worker wears PPE
Storage tank cleaning Sludge Exposure time: 100 hrs/yr
Worker wears PPE
Exposure time: 2,000 hrs/yr
Gas processing Pb-210 film
Worker wears PPE
Sludge treatment workers  
Exposure time: 2,000 hrs/yr
Sludge treatment Sludge Worker wears PPE

Personal protective equipment (PPE) includes respirators, eye protection, and gloves

North Dakota Public Meetings, January 2015

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Well Site Operations Dose Assessment Results
Based on Average Concentrations

Total Dose
Operations Exposure Source (mrem/yr)
     
Mixing hydraulic fracturing fluid Proppant 20

Produced water filtration Filter socks, filter cake 0.47

Pipe cleaning Scale 14
Storage tank cleaning Sludge 3.8
Equipment cleaning at gas Pb-210 film 0.0003
processing
Sludge treatment workers Sludge 1.6

Based on average TENORM concentrations and assuming appropriate use

of PPE, all workers receive a dose significantly less than 100 mrem/yr

North Dakota Public Meetings, January 2015

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Well Site Operations Sensitivity Analysis Results

Maximum Concentration   Average Concentration

 
Operations With PPE Without   With PPE Without
  (mrem/yr) (mrem/yr) (mrem/yr) (mrem/yr)
           
Mixing hydraulic fracturing fluid 23 30   20 26
Pipe cleaning 127 650   14 390
Storage tank cleaning 70 73   3.8 7.4

Equipment cleaning at gas 0.012 670   0.0003 18

processing facility

Sludge treatment 30 85.8   1.6 15.4

The use of PPE can effectively reduce potential exposures for many workers.
Based on maximum concentrations, doses for the equipment cleaning workers
could be elevated even if PPE are used.
It may be necessary to limit exposure time to keep exposures to these workers
below 100mrem/yr.
North Dakota Public Meetings, January 2015
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Accidental Public Exposure Assessment Results

Scenario Maximum Average

Concentration   Concentration
(Exposure Time Over One Year) 
Total Dose Total Dose
 
  (mrem/yr) (mrem/yr)
Child playing with filter socks (24 hrs) 0.21 0.051

Adult exposed to filter socks in a 4.4 0.40

dumpster (40 hrs)

Child playing in area where synthetic 1.4 1.2

proppant has been dumped on the
ground (100 hrs)

These scenarios are not representative of all possible exposures.

For the scenarios modeled, the risks of short term exposure to
improperly disposed of filter socks and synthetic proppant are low.

North Dakota Public Meetings, January 2015

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Transportation Risk Assessment Scenarios and Results
Base Casea Maximum Case
Receptor (1,000 Shipments/yr) (2,000 Shipments/yr)
Dose (mrem/yr) Dose (mrem/yr)
Routine Conditions    
Driver 20 20
Individual 1.6  10-6 3.2  10-6
General populationb 6.5  10-5 1.3  10-4
     
Accident Conditions    
General populationb 3.6 7.2
a
Assumes 25,000 tons/yr TENORM wastes transported to a single landfill, truck capacity of 25 tons,
based on maximum allowable TENORM concentrations from landfill scenarios.
b
Doses to the collective general population are expressed in units of person-rem/yr.

Potential doses associated with transportation of TENORM

wastes are very low both for drivers and members of the general
public.

North Dakota Public Meetings, January 2015

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Landfill Operations and Future Use Scenarios
Landfill Operations
 Up to 25,000 tons of TENORM per year disposed of in a single landfill;
TENORM wastes would comprise no more 10% of the total landfill volume
 Worker exposures
– Waste receiving and handling
– Waste transport within the landfill
– Waste placement
– Workers operating the leachate management system
 General public exposures

Future Use of the Landfill Property

 Onsite resident
 Industrial worker
 Recreational visitor
 Intruder
 Offsite resident
North Dakota Public Meetings, January 2015
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Estimated Allowable TENORM Concentrations Were
Calculated to Ensure Potential Doses Were Below
100 mrem/yr for All Receptors
Allowable TENORM Concentration (pCi/g)
Based on Worker Scenarios Based on Future-Use Scenarios
 Radionuclide pCi/g Limiting Scenario pCi/g Limiting Scenario
     
Pb-210 4,200 Waste Placement 11,000 Intruder
Ra-226 98 Receiving and 130 Resident
Handling
Ra-228 180 Receiving and 700 Intruder
Handling
Th-232 48 Waste Placement 410 Intruder

In general the landfill worker scenarios were more restrictive than the
future use scenarios for all radionuclides.
North Dakota Public Meetings, January 2015
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Calculation of Maximum Allowable Radium
Concentration for TENORM Disposal in the Landfills
The TENORM landfill disposal rule needs to establish a maximum allowable total
radium concentration that
1. Ensures doses to not exceed the recommended limit of 100 mrem/yr for the
general public, and
2. Factors in the possible presence of thorium.

The following calculations were made:

 The ratios of Th-232/total radium and Ra-226/total radium were calculated based
on available waste characterization data.
 The sum of fractions rule was used to calculate the maximum total radium
concentration using these ratios.
 A conservative calculation was run using these ratios plus one standard deviation.
 The results indicated that the 100 mrem/yr dose limit would not be exceeded if
the maximum total radium concentration was 51 pCi/g, assuming a thorium
concentration of no more than 24 pCi/g.

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Recommendations Regarding Regulation of the
Disposal of TENORM in Landfills
 To ensure that potential exposures to any landfill worker or member of the
general public does not exceed 100 mrem/yr
 The average concentration of total radium should not exceed 50 pCi/g of total
radium provided the following conditions were met:
– No more than 25,000 tons of TENORM wastes were disposed of in a single
landfill per year.
– The average thorium activity concentration in the waste did not exceed 24
pCi/g.
– TENORM wastes were covered by at least 2 m (6 ft) of clean cover material.

North Dakota Public Meetings, January 2015

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TENORM

North Dakota’s Journey to Rulemaking

BEGINNINGS

 2013 Oil industry is on the move

– 200+ rigs operating capable of 20,000 feet or more
– 167 Billion barrels of oil in place
– 7.38 Billion barrels are recoverable using current technology
Current Production
as of 3-11-2016

 Rig count 33 as of 3-11-2016

 13,123 producing wells
– 945 wells waiting on completion services
 1,122,100 barrels per day
 1,671,034 MCF/day (natural gas)
 Currently capturing about 87% of natural gas
– 13% flare
 End Result?
– 50,000 to 70,000 wells drilled
2-20 yard Rolloff containers
Problem Solved?

 Effective June 1, 2014, covered, leak-proof containers designated for filter sock
disposal are required to be on-site at saltwater disposal wells at all times and on-
site during the drilling, completion and flow-back phases of all new spud (drilled)
oil and gas wells.
Licensed Haulers

 On March 13, 2014 the Department of Mineral Resources notified all North Dakota
well operators that they must use waste haulers licensed by the North Dakota
Department of Health.
Current Disposal Options

 Less than 5 pCi/g

– Disposal in local landfill

• If they will accept the waste

 5 pCi/g or more

– Oaks (Buckhorn) in Montana

– Clean Harbors (Colorado)
– US Ecology (Idaho)
How much Waste is generated

 47 cubic yards per day

• This is equal to 2 twenty yard roll off dumpsters

 In terms of weight:

– Approximately 119 tons per day

• This could include any of the following:
– Frac sand
– Tanks bottoms
– Scale
– Metal parts including pipe, valves, and other steel
– Filter socks
North Dakota has Raised the Disposal Limit
Effective January 1, 2016

 Argonne National Lab conducted study

– $182,000.00
– Sampling data was not used
– Worked backwards from the public dose limit of 100 mrem
– Calculations based on Special Waste Landfill design
– Acceptable disposal concentration 51.6 pCi/g
– North Dakota decided to use 50.0 pCi/g
Rule Making Process

 Draft rule promulgated late 2013 based on CRCPD SSR part n

– New chapter to the North Dakota Radiological Health rules (33-10-23)
– Some additions include:
• Waste hauler licensing
• Applicant background and criminal history check
• Specific record keeping requirements
• RSO training requirements for certain license types
Public Hearings

 North Dakota rules require 30 day notice of public hearing

 One public hearing is required
 30 day comment period required

 North Dakota held 3 public hearings and extended the comment period to 80 days
Public Comments

 https://www.ndhealth.gov/EHS/TENORM/Rules/NDDoH%20Response%20to%20TE
NORM%20Comments.pdf

 107 pages of comments with department responses

Comment Summary

 Many comments related to Solid Waste rules

– Tribal lands
• Rules do not apply

– Concerns regarding lack of OSHA presence and enforcement

• Response – Beyond the scope of proposed rules
Rule Making Process Questions

• Objection to more waste in ND because it is not in line with the Department mission to protect and enhance health and safety

– The reason for the ANL study was to determine how best to protect the public health because of the dumping scenarios that
evolved prompting the Department to take the action we have taken

• Concern regarding radioactivity in high concentrations

– 50 pCi/g is not a high concentration - ie, medical (millicuries), granite (30 pCi/g), phosphate fertilizers (100 pCi/g)

• The Department had 120 days to review the report and public only had 30 days

– Department reviewed the draft report at two separate times for accuracy to assure that the report addressed the questions
asked in the request for proposals
» First draft on July 9, 2014
» September 2014
» Final Draft – November 12, 2014
» November 24, 2014 ANL report was cleared for public release
Staffing Concerns

 Request for more public hearings

– The law required only one public hearing and the Department held three that were
spread across the state

 There were comments that the Department did not have sufficient staff or
radiation background to regulate this material

– 3 of our staff have more than 20 years experience each in Radiation Health Physics
– The Department has increase staff by 3
ANL Credentials

 Comments were made related to trust and expertise in the study approach and
execution of the study

– RESRAD code and TSD DOSE was developed by ANL and in addition ANL staff have a
extensive experience in this area
Public Exposure Concerns

 Comment that the ANL study did not include oil field worker exposure

– Well site activities are regulated by OSHA

 There were comments related to exposure to those living nearby

– Primary exposure is alpha and beta and because this material is buried under 3 meters
of cover, these concerns are minimal
Radon Issues

 Numerous concerns regarding Radon exposure to workers in the Oil Field

 Data is flawed because the samples were supplied by the oil industry

– Response - No sample data was used. Calculations were based on the 100 mrm annual
exposure limit to the public
Radon Emanation from Landfill

 Concerns regarding Radon emanation through the leachate collection system

– Study conducted at a Montana landfill did not demonstrate significant Radon levels
Field Testing

 Lack of a short turn-around (field) TENORM waste screening method

– The Department has approved a short turn around test based upon the 185 kev peak
with a correction factor - this is considered a screening method

– EPA 901.1 and HASL 300 are analytical methods used

– In addition, there are currently instruments on the market that can give real time
measurements
Personnel Monitoring

 Comments regarding personnel monitoring of landfill workers

– Personnel Monitoring will be required for a period of time for each licensee
Rule Clarification (TENORM)

 RSO Qualifications
 Wanted more exemptions
 Claim that certain portions of the Departments’ regulations do not apply to the oil
and gas industry ie. 33-10-04.2 (Standards for Protection against Radiation)
Decontamination

 Decontamination requirements are not specific

– The rules are specific regarding decontamination in that they must comply with the
requirements in the rules 33-10-03.1

 Vacating premises

– requirements regarding decontamination are addressed in the rules and any calibrated
survey instruments are acceptable
Transportation of Waste

 Labels on containers

– Containers must be labeled so those working in the area are aware of their surroundings

 Containers should have design criteria spelled out

– These requirements are already established by the US DOT

 Waste Haulers reporting

– Waste manifests are required to track the waste

Purposeful Dilution

 Several comments wanting exemptions or clarifications to what may be considered

purposeful dilution

– “TENORM waste shall not be diluted for the sole purpose of making the waste exempt
from the disposal requirements without prior Department approval.”
Rules
CRCPD Suggested State Regulations
sub-part N

 https://www.ndhealth.gov/AQ/RAD/radrules/33-10-23.pdf
Radiation Program Website

https://www.ndhealth.gov/EHS/TENORM/
Waste Streams

 Flow back water – 30 pCi/g

– If licensed material such as Scandium is involved, this material is regulated under NDAC
33-10-12

 Produced water – 30-50 pCi/g

 Tank Bottoms – 500 pCi/g
 Pipe Scale – 30,000 pCi/g
Licensees

 Treatment Facilities
– TENORM concentrations to be determined when the material comes off of the:
• Filter Press
• Centrifuge
• Shaker
 Decontamination companies
 Roustabouts
 Work Over companies
 Landfill
Licensees Continued:

 Waste Haulers
 Vacuum Trucks
Approval Process

 8-12-2015 Approved by North Dakota Health Council

 Attorney General opinion state that statutory requirements were met
 Legislative Rules Committee approved
– Published by the Legislative Council
• Once published, rules are final
– January 1, 2016
Next Steps

 Learning the Oil and Gas industry

 Licensing entities that handle TENORM
 Review and Licensure of Special Waste Landfills
 Track Waste
 Conduct periodic inspections
 Evaluate the Natural Gas processing facilities
 License Pipe cleaning operations
QUESTIONS?

Dale Patrick
dpatrick@nd.gov
701-328-5188