NORM - Radioactive Materials in Oil and Gas Production

NORM stands for Naturally Occurring Radioactive Materials. Most people are unaware that NORM is brought to the surface of the land in oil and gas development, typically with associated formation water that comes up with the oil and gas. Commonly found elements in NORM include Uranium, Thorium, and Radium, and the levels encountered are typically very low.

When brought to the surface, the produced formation water is then separated from the oil and gas and placed into storage tanks or pits, where it is usually re-injected back into the earth. NORM cannot be seen, and for the most part, does not pose a hazard to persons or the environment.

However, concentrations of NORM can pose a hazard. When the holding tanks or pits are used for a long time, concentrations can occur in pipe scale and accumulated sludge. When concentrations occur, it is up to oil and gas operators to identify and adequately mark or identify contaminated materials.

Regulations and procedures are set by state, not federal, government. Across the country, there are varying levels of regulation. For example, some states do not require decontamination of the land until the lease ceases and plugging of the oil and gas wells is imminent. This could mean many years, even decades, elapse before decontamination is required. It also leaves the question open of who is responsible for cleanup if the operator becomes insolvent, and bonding requirements may not come close to the actual clean up costs the public will ultimately bear the burden of.

While NORM is well known now, and companies have more responsibility for identifying and addressing NORM than they used to, this was not the case until the 1980s. Prior to this time, there was not much awareness about NORM. As a result, older well sites could still have environmental contamination around production and disposal facilities. This, in turn, could lead to ground or surface water contamination.

Further, while disposal wells are common now, it used to be more common for NORM waste to be mixed with the surrounding soil and spread across the land. This procedure is still used in some places today. In older production sites, it is much more likely that the nearby soils could have “above-background” levels of NORM concentrations.

For the past 30 years, oil and gas producers have become more aware about NORM, and its potential costs and liabilities. For that reason, they have included cautionary language about NORM in their contracts and other documents transferring leases to one another. But, what about the leases themselves?

Most oil and gas producers do not voluntarily include environmental protection language in their leases and surface agreements. And most owners do not know to ask.

For more, please visit: https://pubs.usgs.gov/fs/fs-0142-99/fs-0142-99.pdf