Api publ 7100 1996 scan (american petroleum institute)

This matrix summarizes the maximum, average, and minimum disposal cost per drum from each region to each disposal site; it also adds in the transport costs to give the total disposal c

ESTIMATES OF NORM WASTES

Introduction

NORM accumulation data was collected from oil and gas producing states in the U.S., as depicted in Figure 1 The responses to the questionnaire were primarily organized by individual oil company regions, with most regions encompassing multiple states Due to the varying state groupings by each company, the analysis was conducted using five distinct regions Figure 1 visually represents the states contributing to the data and the grouping used for the analysis.

The NORM survey questionnaire was distributed to API member companies, yielding 50 responses that account for about 46 percent of the domestic U.S oil, gas, and gas condensate production capacity The findings from these responses are summarized in the accompanying tables and appendices.

Total oil and gas condensate production is expressed as a percentage of each region's overall output Annual production figures are sourced from the Oil and Gas Journal for comparison There were no responses regarding Naturally Occurring Radioactive Material (NORM) in natural gas.

The data for oil and condensate production was obtained in section I 6.1 of the questionnaire and is shown in Appen- dix C This data was cross-checked with reported oil and

Region 3 gas condensate figures from the Dwights Energydata, Inc

An information database was utilized to accurately divide production data by state and region for the responding companies This approach enabled the prorating of figures for the total accumulated NORM up to December 1992, as well as the 1993 annual NORM accumulation, reflecting the total oil and gas condensate production in each region Additionally, the Dwights information facilitated a more precise division of responses by state and grouping by region.

The regional groupings of states for the questionnaire replies were adjusted as shown in Figure 1, as no two replies had the same grouping Two survey responses reporting NORM drum disposal costs of $20,000 per drum were excluded due to unusual operational issues that are not expected to happen again The first high-cost NORM disposal was attributed to the loss of well use caused by junk steel in the well bore, while the second was due to an unusable well bore from equipment lodged inside.

1.1 I COMMENTS ON THE NORM SURVEY DATA

The NORM surveys did not use a single, consistent survey procedure or dose rate decision criteria For example,

Figure 1-Responding States Grouped Into Regions

Provided by IHS under license with API

Table 1-Oil and Gas Questionnaire Replies 1992

Region Gulf Coast Mid-Continent Rocky Mountains California Alaska Total

(Percentage of region responding) (44%) (20%) o00 BPD (100 Percent) Ref [ 5 ] 2233 1583 the distance of the detector from the item being surveyed

The dose rate criteria for Naturally Occurring Radioactive Material (NORM) were consistently set at either 25 or 50 micro Roentgen per hour across various contexts, including equipment, drums, ground, and produced water pits Measurements of NORM varied significantly, ranging from 1 centimeter to 18 inches However, the data reported did not account for the number of items surveyed that were free of NORM, which likely outnumbered those containing it.

Figure 2, prepared from the previously unpublished Loui- siana Mid-Continent Oil and Gas Association (LMOGA)

According to NORM survey data, 90 percent of the NORM stored in 1992, based on a 25 microWh decision criterion, exhibited a specific activity of less than 100 picocuries per gram.

Figure 2 illustrates the distribution of stored Naturally Occurring Radioactive Material (NORM) by specific activity and percentage of total stored per activity range Surveys of oil, gas, and gas condensate equipment reveal that detecting NORM on external surfaces can be challenging, particularly when the specific activity is below 100 pCi/g and the action level is set at 50 micro R/h Consequently, only NORM with a specific activity exceeding 100 pCi/g, which constitutes about 9 percent of all NORM, is reliably detected Additionally, less than 1 percent of NORM has a specific activity greater than 1000 pCi/g Several factors influence the detection and reporting of NORM, including the sensitivity of survey detectors, the action level for reporting, oil and gas production rates, the ratio of produced water to oil, the use of scale inhibitors, and the percentage of produced water that is re-injected versus treated at the surface.

The NORM information presented in this publication was gathered through a survey questionnaire, with Appendixes A through G showcasing examples of the questionnaire, the data collected, and various summaries Each appendix is described in detail to provide clarity on its contents.

Appendix A presents a typical questionnaire response, highlighting the significant lack of NORM data related to gas production, with only one response providing NORM-specific activity details Figure 3 summarizes the dose rate data for the accumulated NORM Appendix B outlines various costs associated with NORM disposal jobs and programs, reflecting the data collected from the questionnaire responses, which are further detailed in Appendix C This appendix features the Questionnaire Survey Replies Database, where the survey responses for oil and gas condensate production were cross-verified with data from Dwights Energydata, Inc to ensure accurate representation of 100 percent of production across all regions.

A NATURALLY OCCURRING RADIOACTIVE MATERIAL DISPOSAL COST STUW 3

Dose Rate Ranges, in microlm

Figure %Drums of Stored NORM by Dose Rate

Corrected to Percent Production (From 1993 API Survey)

Appendix D contains a transportation cost matrix by region to permitted disposal sites (1993) Estimates were derived from transport company rate sheets and modified through discussions with oil and gas producing companies

Rates are for exclusive use full-load vehicles

Appendix E presents a summary of actual disposal costs per drum for plug and abandonment, as detailed in Appendix C It includes the maximum, average, and minimum costs associated with NORM disposal through injection or encapsulation placement, with the majority of the data sourced from Region 1.

Appendix F provides a comprehensive overview of NORM disposal costs across different regions, detailing the maximum, average, and minimum disposal costs per drum for each disposal site It incorporates transportation costs to present the total disposal expenses for the annual NORM accumulation and the total NORM material from each region By multiplying the number of accumulated NORM drums per region by these costs, the document outlines the range of disposal costs for accumulated NORM in each area.

The annual NORM accumulation rates for all five regions, as shown in Table 3, are multiplied by the minimum and maximum average transport and disposal costs per drum from Appendix F, resulting in the annual NORM transport and disposal cost range summarized in Table 9.

The five regions are individually summarized, and their totals provide the overall transport and disposal costs for all accumulated Naturally Occurring Radioactive Material (NORM) Additionally, the annual disposal cost is calculated based on the yearly volume of NORM accumulated, as detailed in Section 4.3.

Appendix G outlines the accumulation of Naturally Occurring Radioactive Material (NORM) categorized by source type The summarized data from responses are organized for comparative analysis based on the NORM-generating sources The significant accumulation reports (#137 and #146) were verified with the responding companies, confirming their accuracy and representing the historical NORM accumulations effectively.

Volumes of NORM Waste-Past, Present and Forecast

The survey responses account for 46 percent of the domestic production of oil, gas, and gas condensate To estimate the total production, the ratio of oil and gas condensate production from the Oil and Gas Journal was applied to the reported NORM drum numbers for each region, thereby representing 100 percent of domestic oil and gas condensate production, as detailed in Table 2.

The U.S oil and gas producing states that provided responses, as illustrated in Figure 1, have been categorized into five regions to streamline the calculation of NORM disposal costs Many participating companies operate across various state groupings, with some regions not specified by individual states In such instances, the survey data was prorated based on the total production across the respective states and regions.

Region I , the Gulf Coast survey, reported oil, gas, and gas condensate production was 97 1.62 thousand barrels per day

(MBPD) (43.5 percent of the actual 2333 MBPD [3] (100 percent) produced in Region 1) Hence the prorating factor is (lOO/43.5) = 2.3 The prorating factors for Regions 2 , 3 , 4 , and 5 were calculated in the same manner

Table 2-NORM Generated Per Region From 1 O0 Percent of Producers

Denvation of Production Multiplier to 100 Percent mbpd

Oil and gas journal ave 2,230.0 1,559.0

Table 3 calculates the annual NORM accumulation rate from the reported annual rates contained in the survey replies

The annual reported quantities of NORM generated for

Regions 1, 2, 3, and 5 calculate their annual NORM generation rate by multiplying a fraction of each region's oil and gas production by a specific factor from Table 2, ensuring that the total production for each region equates to 100 percent.

The NORM survey dose rate decision criteria of 50 microRh is assessed on the exterior of the steel components surveyed, but no standardized measurement protocol was employed for the readings Several factors impact the accuracy of these measurements, including the varying thicknesses of the steel equipment, the distance and orientation of the detector relative to the surveyed component, the amount of NORM present within the component, and the potential interference from non-radioactive barium scales.

Because of these sources of error and external decision criteria, it is difficult to detect NORM with a specific activity less than i00 pCi/g

The accumulation of NORM in oil and gas equipment

(see Figure 2) has a relationship between the quantity produced and the specific activity such that, based on the

According to LMOGA data, 90 percent of the accumulated NORM is below 100 pCi/g, making it difficult to detect through external surveys unless conducted meticulously by trained and experienced NORM technicians.

The accuracy of readings for Naturally Occurring Radioactive Materials (NORM) can be significantly affected by various difficulties, even in controlled laboratory conditions As a result, the reported quantities of NORM may be underestimated by a factor ranging from 2 to 10 To account for this discrepancy, both the annual and accumulated quantities of NORM are adjusted by multiplying them by a factor of 2 to 10 This document specifically utilizes a factor of 10 to calculate the total annual accumulation of NORM and the quantities accumulated over many years of production.

Table 3 presents the annual accumulation rates of NORM reported by Regions 1, 2, 3, and 5 These figures are adjusted by the multiplication factor from Table 2 to reflect 100 percent of the production and are further multiplied by 10 to account for the challenges in detecting lower specific activities of NORM.

Figure 3 presents data derived from questionnaire responses, illustrating the quantities of stored NORM categorized by dose rate ranges: 25-50, 50-100, 100-500, 500-1000, and over 1000 microRh The analysis of these readings highlights the distribution of NORM storage based on varying dose rates.

A microRh measurement of 50 indicates that it represents NORM levels exceeding 100 pCi/g, as illustrated in Figure 2, which shows that this accounts for 10 percent of the total NORM accumulated The overall quantity of NORM, if completely identified, can be expressed through a specific equation.

Table >Annual NORM Accumulation Rate 1993

Total NORM NORM Reported Prorated to 1 0 0 Percent Total Per Annum Multiplier for Accumulation Per

Region > 100 DCi/P; Accumulation Prorated Drums All NORM Annum Drums

Note: Using the multiplier IO as previously discussed gives a total annual NORM accumulation of 142,000 drums

’Reported number represents NORM greater than 100 pCiJg; from Figure 2 that is 10 percent of the total annual accumulation

1.2.3 CALCULATION OF THE NORM ACCUMULA-

From the survey results, no NORM was reported for Region 4 However, a 1995 NORM survey of oil and gas production equipment in California by the California

Department of Health Services Radiological Health Branch

A survey conducted by RHB revealed the presence of Naturally Occurring Radioactive Material (NORM) in certain oil and gas equipment that had been decommissioned The locations chosen for the survey aimed to enhance the likelihood of detecting NORM, which suggests that the preliminary detection frequency of 23 percent may not accurately reflect the actual occurrence rate previously documented.

3.42 percent [6] From recent NORM survey work in Cali- fornia by a number of oil and gas companies, it has been learned that the occurrence of NORM appears to be lower in

California exhibits a higher occurrence of NORM compared to the Gulf Coast states Based on data from recent reports and discussions with the RHB, an estimate of NORM prevalence in California has been derived by comparing it to Region 2 (Mid-).

Continent), in both oil and gas production and NORM incidence reported [6] and calculated for the states grouped in each region

Reported oil and gas condensate production

From questionnaire = 323,000 bpd Reported annual NORM accumulation Total annual oil and gas production [3] = 1,583,000 bpd Total annual NORM generated

Reported oil and gas condensate production

From questionnaire = 145,000 bpd Reported annual NORM accumulation Total annual oil and gas production [ 31

1.2.4 SUMMARY OF NORM QUALITIES FOR

Table 4 summarizes accumulated NORM in drums, tubulars, vessels, process equipment, ponds, and on sites The questionnaire replies and the multipliers developed in Table

The reply data was prorated to reflect 100 percent of each region, with the exception of Region 4, which was calculated separately Table 4 provides a summary of the total accumulated Naturally Occurring Radioactive Material (NORM) from all sources, based on the responses, representing the entire industry.

Region 4 is a calculated value for a 15-year accumulation based on the annual value calculated in Table 3

The minimum annual generation rate of NORM is 142,390 drums, based on reported data This figure reflects the total accumulation of NORM, which amounts to 10,056,597 drums, representing all domestic oil and gas condensate production in the U.S.

Table 5 displays the NORM quantities categorized by specific activity for each region, utilizing the graph in Figure 2 alongside the total accumulated NORM from Table 4 to determine the actual number of drums within each specific activity range.

Figure 2 shows that 92 percent of all NORM is less than

200 pCi/g, and 7 percent is greater than 200 but less than

Reference List

Publications cited in other sections of this document are listed here

1 W Russo, “Draft Diffuse NORM Wastes-Waste

Characterization and Preliminary Risk Assessment,”

Potential Impact of Environmental Regulations on Oil and

Gas Exploration and Production Industries, March 1995

6 A National Survey on Naturally Occurring Radioactive Materials (NORM) in Petroleum Producing and Cas Pro- cessing Facilities i989 Otto

7 Unpublished Report, Louisiana Mid-Continent Oil and

8 A McArthur, G Reed, and B Holland, SPE # 23383,

“Evaluating the Real Risks of Radioactive Scale in Oil and Gas Production, ” ICI Tracerco

9 American Petroleum Institute Report, Methods for Mea- suring Naturally Occurring Radioactive Materials in Petro- leum Production Equipment, December 1989.

DISPOSAL OPTIONS AVAILABLE

Burial Sites

All placement and burial sites will be supported by 10,000-year perpetual care funds and comprehensive records of all parties involved in supplying NORM materials If future regulations require site reopening and remediation of NORM, costs exceeding the perpetual care fund may be shared by site users if the government cannot cover them Consequently, utilizing a placement and burial site may entail future financial risks that are difficult to quantify Each site has specific acceptance criteria, and only certain activity limitations were evaluated in this study.

Surface Treatment

To effectively lower the concentration of low-level Naturally Occurring Radioactive Material (NORM) below the regulatory threshold of 5 pCi/g, a dilution and mixing process involving materials with less than 200 pCi/g is proposed This method necessitates extensive land areas and significant amounts of NORM-free organic material to adequately treat the accumulated NORM.

1,000,000 drums of NORM with an average specific activity of 50 pCi/g to less than 5 pCi/g would require more than 10,000,000 barrels of material with no NORM component

The processing dilution and deep well injection of Naturally Occurring Radioactive Material (NORM) presents a cost-effective disposal solution, utilizing reusable wells and facilities Currently, there is an acceptance limit of 2000 pCi/g for NORM injection When geological factors are considered and operations comply with regulations, this method can offer local disposal services across oil and gas-producing states at a reasonable cost One commercial injection facility is already operational, with additional facilities expected to be permitted based on demand density.

A NATURALLY OCCURRING RADIOACTIVE MATERIAL DISPOSAL COST STUDY 7

Table %Per Drum Disposal Costs for NORM

Options Type Radium Acceptance Per Drum (55 Gallons)

I Burial No limit on specific activity 5395 $515 S730

No limit on total activity

4 Injection Class U well after dilution

7 Encapsulation in tubulars in plug and abandoned wells

8.9 Injection Class Il Wenswdl bores and geological formations

No limit on total activity

Radiochemical analysis Physical properties check Transportation

Physical propenies check Chemical analysis EPAIDOT NOW analysis Packing

Transport Physical check Chemical analysis Radiochemical analysis Packing

No cost Steel purchase value pays for tmnsport to pon F.O.B

All inclusive costs from actual reporis for oil and gas costs

All inclusive costs from actual reports for oil and gas costs

Note: Minimum figure forecast to reduce with more competitive services and reusable injection well.

Recycling of Steel

The purchase of NORM-containing steel for processing and recycling in China represents the most cost effective method to dispose of scrap steel containing NORM

Recycling high-grade NORM-containing scrap steel is a commendable goal; however, it poses potential future liabilities for service users To safeguard personnel and the environment, it is essential to implement and enforce strict procedures.

The U.S steel recycling industry uses highly detailed procedures and sensitive inspection equipment to prevent the accidental smelting of radioactive-contaminated steel

Current research work into smelting NORM-containing steel will help with the development of procedures to enable the safe recycling of NORM-containing steel in the U.S.

NORM Recycling Into Shielding Bricks

A recent industry solicitation has emerged for the shipment of NORM waste to Russia, proposing the reprocessing of this waste into brick-like forms These bricks would be entombed in the Chernobyl reactor, contributing to a managed perpetual care fund intended for 200,000 years While this disposal option is technically feasible, it is pending detailed cost analysis and regulatory approval An independent risk assessment is recommended to evaluate potential financial, political, and operational implications associated with this service.

Plug and Abandonment of Wells-Encapsulation and Injection

Oilfield operations have introduced innovative techniques for the disposal of Naturally Occurring Radioactive Material (NORM) into well bores and geological formations, which are currently being sealed and abandoned with cement This NORM disposal process may involve encapsulating the material in steel tubulars that are inserted into the well bore or mixing it with other substances.

NORM fluid slurry is injected into well bores or geological formations, often at high pressures that can fracture the rock and facilitate the injection of large quantities of NORM Detailed regulatory approval procedures govern all plug and abandonment operations, whether or not they involve NORM disposal, and all states mandate the reporting of these operations There are no geographical restrictions on oilfield disposal operations, as long as suitable geological formations exist and regulations for plug and abandonment disposal are enforced All states involved in oil and gas condensate production have established these necessary regulations.

A commercial project has been documented involving the process of injecting and disposing of Naturally Occurring Radioactive Material (NORM) into a Class II well, which is still operational for other non-NORM Class II materials.

C O S T ESTIMATES FOR EACH DISPOSAL OPTION

Disposal Options Review

Low-level radioactive burial sites can be either privately or publicly owned For oilfield Naturally Occurring Radioactive Material (NORM), it is essential that the site has a permanent care fund to ensure inspection, care, and maintenance for a duration of 10,000 years This timeframe is roughly seven times longer than the 1,620-year half-life of radium-226, the isotope with the longest half-life found in NORM associated with oil and gas production.

The NORM designated for burial sites undergoes thorough characterization, focusing on isotope content, moisture-free chemical composition, and physical properties All companies utilizing the site will be issued a disposal certificate, confirming the proper placement of their waste within the facility.

Site acceptance criteria encompass various limits, including the type and concentration of isotopes, such as a maximum of 2000 pCi/g for radium 226 at one site, while another site may have no concentration limit for radium 228 Additional criteria involve the chemical composition, physical form, and free liquid content of materials, as well as restrictions on annual quantities from a single generator and total yearly quantities Furthermore, these criteria address classes of hazardous materials, the requirement for a state NORM site use permit, and stipulations for packaging in approved containers or bulk shipments.

Federally permitted facilities facilitate the transfer of ownership of NORM material once it meets the acceptance criteria for burial Upon acceptance, title ownership is transferred to the federal government, with future site management costs anticipated to be covered by the perpetual care fund established during the site's operational phase.

Louisiana allows the treatment dilution of Naturally Occurring Radioactive Materials (NORM), with input materials capped at 200 pCi/g of total radium Nonhazardous oilfield waste (NOW) can be combined with NORM waste, and the mixture must be treated with clean material until the specific activity drops below 5 pCi/g of total radium Once diluted, the material can be released as unregulated, permitting its reuse or disposal in a permitted landfill, subject to other non-NORM regulations.

Since 90 percent of the NORM is less than 100 pCi/g, this disposal option could accept the bulk of all NORM produced Treated NORM that is less than 5 pCi/g radium is below regulatory concern; it is no longer considered to be a radioactive material The volume of clean materials needed to dilute the IO million drums of NORM to less than 100 pCi/g would be very large

The treatment site is equipped with a drainage system for leachate collection and utilizes permitted Class II wells for deep well disposal The permitting process for these disposal wells includes a performance bond to ensure coverage for the costs associated with the closure and abandonment of injection wells This method has been successfully implemented in numerous Class II wells over the years, demonstrating its reliability and effectiveness.

STD.API/PETRO PUBL 7100-ENGL 1 9 9 b W 0 7 3 2 2 7 0 0 5 b ô 0 7 4 2 5 T m

A NATURALLY OCCURRING RAO~OACTIVE MATERIAL DISPOSAL Cost STUDY 9 acceptance criteria to that for burial may be required and should be obtained from the facility operator

Injection disposal is a new method for managing Naturally Occurring Radioactive Material (NORM) This service involves the dilution treatment of NORM and other materials, allowing for safe disposal into a Class II injection well.

NORM levels up to 2000 pCi/L will be diluted to 30 pCi/g before being processed The resulting fluid will be hydrated and have viscosifiers added to ensure the NORM remains suspended for injection into Class II wells These NORM fluids will be injected into deep geological formations situated below underground sources of drinking water.

NORM is reduced to and is manifested as a NOW material

Acceptance criteria similar to that for burial may be required The actual criteria should be obtained from the facility operator

Recycling of NORM-containing steel production equipment represents a maximum of IO percent of the total

The accumulation of NORM volume allows recyclers to purchase NOW-containing steel, potentially generating a small income that can offset transportation costs This arrangement enables zero-cost disposal for NORM-containing production equipment through efficient shipping solutions.

The recycler's facility lacks information regarding the protection of workers and the environment Although international agreements advocate for material recycling, it is essential to consider potential future liabilities.

Title transfer occurs on receipt for shipment Even where no compliance requirements exist, there may still be a signiủ- cant liability to protect workers and the environment

Acceptance criteria stipulate that components must be supplied as sealed units to effectively contain all Naturally Occurring Radioactive Material (NORM) It is acceptable for these units to have minimal or no fluid content Additionally, there are no restrictions on dose rates, total activity, or the quantity of materials involved.

NORM/NOW waste materials are being repurposed into building bricks for use as shielding at the Chernobyl permanent care site The initial shipment has been successfully dispatched to Russia, with no issues reported thus far.

Transfer of title to the waste occurs on its acceptance for shipment and in compliance with the shipping manifest

The acceptance criteria for NOW waste, as defined by EPAIDCrT, do not restrict the specific or total activity, provided the material complies with the standards The allowable limit for free liquids is 10 percent, and NORM must be packaged in 55-gallon drums according to DOT 17E regulations.

17H, or other acceptable container is required NORM-containing steel is also accepted

3.1.6 PLUG AND ABANDONMENT OF WELLS- ENCAPSULATION AND INJECTION 3.1.6.1 Encapsulation

Well bore encapsulation is an effective disposal method for plugging and abandoning wells In this process, Naturally Occurring Radioactive Material (NORM) is securely sealed within tubular goods, which are then placed into the well bore A cement plug is subsequently poured on top, and the well is cut off below ground level before being abandoned.

Cost Estimates

Table 6 outlines the disposal costs per drum for various available options for NORM, with the data sourced from published rate sheets for currently offered services.

Table 6 presents the actual disposal costs per drum for various NORM disposal options available in 1993 It summarizes commercial options 1 through 6 by location, outlines radium acceptance criteria where applicable, and provides a range of disposal costs per drum, including minimum, average, and maximum figures.

All disposal options come with specific acceptance criteria, which may include costs for radiochemical analysis ranging from \$100 to \$500 per sample, chemical metals analysis between \$250 and \$500 per sample, and pretreatment washing volume reduction priced at \$10 to \$25 per drum Additional expenses may involve permitting manifesting, generator administration costs, and non-NORM waste disposal fees.

Thc extra cost of these analyses and this processing could increase the total disposal cost per drum to equal or consid- erably exceed the average cost per drum

Disposal options 7, 8, and 9 for the plug and abandonment of wells reflect the actual experience of the oil industry while disposing of NORM through the placement of

NORM can be introduced into wells through encapsulation in tubular pipes or by injecting it as a slurry into the well bore and geological formations For a detailed discussion on these methods, refer to Sections 2 and 6 It is important to note that the inclusion of a disposal option does not indicate its endorsement or recommendation for use.

Table 7 presents the minimum and maximum average costs for transport and disposal per drum across various regions The disposal costs, including transportation, are detailed in Appendix F and correspond to the disposal option numbers listed in Table 6 For instance, a cost of $212 (4) indicates that this is the minimum average expense for transport and disposal.

$21 2/drum for disposal option 4 from Region 1

To calculate the minimum and maximum average transport and disposal costs per region, multiply the number of drums by the minimum and maximum average cost per drum, respectively, while considering specific activities.

Based on the actual reported costs and the accumulated

The national cost impact of implementing and enforcing NORM regulations on the U.S oil and gas industry, based on the aforementioned assumptions and calculations, is estimated to be around $2.3 billion for the transport and disposal of accumulated NORM.

$10.9 billion This cost would be spread over a number of years (for example, 25 years at $92 to $436 million per

Table 8 presents the average disposal costs for Naturally Occurring Radioactive Material (NORM) by region, focusing on higher specific activity NORM, which constitutes 10% of total NORM exceeding 100 pCi/g In 1992, the total annual disposal cost across all five regions was $7.12 million, reflecting an average cost of $540 per drum for transport and disposal This figure represents the minimum annual cost associated with NORM disposal.

Table 9 presents the estimated annual costs for the disposal of NORM accumulation, derived from prorated figures in Table 3 and average transport and disposal costs from Appendix F The analysis indicates a minimum average cost of $27 million and a maximum average cost of $227 million for the transport and disposal of NORM accumulated over the year.

Table 7-Accumulated NORM Disposal Costs Derived Using the Minimum and Maximum Average Costs Per Drum

Avg Avg Avg Avg Avg Avg

Specific Activity Region Min Mm Min Mm Min Max Min Mm

Cost per Drum (Disposal Option) 212 (4) 1081 (7) 212 (4) 1081 (7) 306(6) 1081 (7)

2 Cost per Drum (Disposai Option) 231 (4) 1081 (7) 231 (4) 1081 (7) 320 (6) 1081 (7)

3 Cost per Drum (Disposai Option) 231 (4) 1081 (7) 231 (4) 1081 (7) 320 (6) 1081 (7)

4 Cost per Drum (Disposal Option) 231 (4) 1081 (7) 231 (4) 1081 (7) 306(6)+ 1081 (7)

Cost per Drum (Disposal Option) 346 (4) IOSI (7) 246 (4) 1081 (7) 320 (6) i081 (7)

Avenge range of NORM transport and disposal for regions 1-5 (in $Millions) $2329410.871

Table +Annual 1992 NORM Disposal Costs for NORM Over 100 pCVg

(10 Percent of Total-Average Cost by Region)

Actual Reported Annual Accumulation Drums (10% of Total)

Actual Reported Average Cost per Drum Total Cost in Millions

'No reported NORM disposal in California

Table +Annual NORM Disposal Cost Range Using Minimum and Maximum Average Costs Per Drum

Specific Activity Region Min Max Min Max Min Mm Min M3X

Cost per Drum (Disposal Option) 212 (4) 1081 (7) 212 (2) 1081 (7) 306 (6) 1081 (7)

2 Cost per Drum (Disposal Option) 231 (4) 1081 (7) 74 (4) 3333 (7) 151 (6) 3333 (7)

Cost per Drum (Disposal Option) 74 (4) 3333 (7) 74 (4) 3333 (7) I51 (8) 3333 (7)

Range of NORM iranspon and disposai for Regions 1-5 (in SMillions) $40-5227

SECTION &INDUSTRY-WIDE DISPOSAL COST IMPACT

The annual volume of Naturally Occurring Radioactive Material (NORM) accumulated, along with associated transport and disposal costs, was calculated based on questionnaire responses that accounted for 46 percent of domestic oil, gas, and gas condensate production in the U.S.

Some 10 million drums of NORM materials were accumulated as of December 1993 in the oil and gas producing states The Region 1 Gulf Coast states figure of 296,000 drums would cost an average of $63 million to $320 million to transport and dispose of to one or more of the nine real disposal options available in 1993 These significant costs do not include the costs to survey, sample, remediate, and place the NORM into drums or containers ready for disposal The cost impact to develop, implement, and manage programs for compliance with NORM regulations will represent an additional significant cost that could double the NORM transpon and disposal costs documented in this publication

Table 7 summarizes the cost impact for transport and disposal of accumulated NORM for the five specific regions

The total costs for the oil and gas industry to implement Naturally Occurring Radioactive Material (NORM) programs, in current dollars, are likely to increase significantly This includes expenses related to meeting both proposed and actual NORM regulations for the remediation of tubulars, equipment, and sites, as well as the transportation and disposal of these materials.

By the end of 1993, the accumulated cost of NORM is estimated to be between $2.3 billion and $10.9 billion, with the lower estimate being more realistic due to potential volume discounts on transport and disposal The large volume of 10 million drums requiring remediation also contributes to economies of scale This cost will be spread over many years as production fields are gradually shut down and abandoned.

The significant variation in reported volumes of accumulated Naturally Occurring Radioactive Material (NORM) across different regions can be attributed to several factors These include the actual quantity of NORM present, the age of the oil fields, the duration and scale of production activities, and the production technologies employed for managing produced water and solids, such as surface treatment or re-injection Additionally, the level of NORM surveying conducted and the necessity for regulatory compliance and precise reporting also play crucial roles in these discrepancies.

Annual NORM Accumulation

The survey replies provided the 1993 estimates of the annual NORM accumulation rate The most commonly used

The NORM survey criteria established an external dose rate threshold of 50 microRh, measured on the outer surface of components containing NORM This external dose rate signifies that the specific activity of NORM exceeds a certain level.

The data shows that 90 percent of the Naturally Occurring Radioactive Material (NORM) is below 100 pCi/g Consequently, the annual accumulation rate, adjusted for full production volumes, is increased tenfold to calculate the total annual amount.

NORM accumulation figure for all specific activities of

142,000 drums per year Other studies argue [ i ] that this annual volume estimate of NORM is low by an order of magnitude

Utilizing the lowest average cost disposal options for each region, the total annual transportation and disposal cost amounts to $27 million, as indicated in Table 9 Conversely, in a worst-case scenario that considers the highest average NORM transport and disposal costs, the total expenses could significantly increase.

NORM disposal cost of $227 million per year

The total expenses associated with the survey, sampling, analysis, remediation, and containerization of annual NORM accumulation can significantly increase The minimum average cost for NORM transport and disposal, initially estimated at $27 million, has the potential to double to $54 million.

Summary of NORM Transport Disposal Cost Impact by Region

Table 10 illustrates the impact of the NORM transport and disposal cost on each of the five regions

Table 1 &NORM Transport and Disposal Cost by

Cost in Millions Cost in Millions

Data from the 1992-93 survey in this region is considered reliable, as it reflects responses from companies accounting for 44 percent of the annual oil and gas condensate production During this period, management and survey programs for Naturally Occurring Radioactive Material (NORM) were also being implemented to comply with regulatory requirements in Louisiana, Mississippi, and Texas.

Note: The Gulf Coast, Region 1, has the most w i d e s p d NORM regulations

Data from Region 2 indicates that companies contributing to 20 percent of the area's annual oil and gas condensate production have reported significant NORM accumulations Two key reports highlight these findings: one details NORM in produced water pits and ponds within a major production system, while the other focuses on NORM sludge and site accumulations Both reports are confirmed to accurately represent historical NORM accumulations in the region over many years As shown in Appendix G, the majority of NORM accumulation is attributed to sludge found on sites or in produced water ponds and pits.

This data represents only 13 percent of the total production of this region and is also heavily biased by one report of

NORM accumulations in surface pits This reply was checked with the responding company and confirmed to be accurate of their NORM accumulation experience

Up until the end of 1993, California data did not report any detection of Naturally Occurring Radioactive Material (NORM) However, surveys conducted in 1995 by the California Department of Health Radiological Health Section confirmed the presence of NORM, leading to new estimates for accumulated levels.

NORM and the annual accumulation were calculated from the results reported for Region 2 and corrected for the differences in total production of oil and gas condensate between Regions

2 and 4 This assumption is thought to be reasonably consistent with early verbal reports of the state NORM survey results

The data from this region is fully reliable, representing 100 percent of production Since the inception of operations, Alaskan oil and gas production has consistently re-injected produced water, effectively returning most Naturally Occurring Radioactive Material (NORM) to the formation Ongoing scale inhibitor management programs play a crucial role in minimizing accumulated NORM Consequently, issues like increased water production, well corrosion, and pressure loss are the primary factors driving the need for production well repairs, rather than concerns related to NORM scale formation.

Conclusion

In 1992, the disposal cost of Naturally Occurring Radioactive Material (NORM) from the U.S oil and gas industry was $7.12 million, primarily based on Gulf Coast data Annually, the transportation and disposal of 142,000 drums of NORM across the industry is estimated to cost between $40 million and $227 million, depending on current and proposed regulations Additionally, remediating the 10 million drums of NORM accumulated over years of production could range from $2.3 billion to $10.9 billion, with costs spread over many years related to the lifespan of each producing field Notably, no responses indicated NORM from gas production, despite its known existence and potential cost implications Furthermore, NORM does not occur in every oil and gas well in the U.S., and the significant variations in its formation necessitate state-level regulation.

FOR DISPOSAL ANALYSIS

The analysis of the questionnaire involved surveying all business units within each responding company To ensure accuracy, the oil and gas condensate production figures from section 1.6.1 of the questionnaires were cross-verified with the Dwight Energydata Services, Inc database for each region, using Dwight's figures in cases of discrepancies This approach facilitated the derivation of more precise production figures for each response.

In this document, the average daily oil and gas condensate production for 1993 was calculated based on data from June 30 to December 31, resulting in a figure of O00 bpd To analyze production by region, adjustments were made to reflect the reported percentages for each area Notably, replies 102, 120, and 148 were excluded from the disposal cost calculations due to significant uncontrollable costs related to disposal well issues The referenced drums are 55 gallons, equivalent to 7.35 ft³ NORM volumes for tubular goods were determined using a scale thickness of 0.25 inches on the inner surface, converting to equivalent drum measurements Total NORM accumulations were calculated by summing specific sections outlined in the document.

The term "P and A," which stands for "plug and abandon," refers to the oilfield practice of injecting concrete and implementing necessary regulatory precautions to ensure a well is safely abandoned Additionally, the cost analysis is detailed in section 3 of the questionnaires.

Appendixes A and B indicate the following:

1 Plug and abandonment of well with NORM injected as a fluid suspension

2 Plug and abandonment of well with NORM encapsu- lated in sealed tubular goods and placed into the well

3 Plug and abandonment of well with NORM injected as a fluid suspension and the well is held available for additional NORM disposal operations

Transport estimates are calculated based on 80 drums of Naturally Occurring Radioactive Material (NORM) per load for a full-load exclusive use vehicle The annual reported NORM generation rate is derived from an external dose rate of 50 microRh on the surfaces of steel components, indicating a specific activity exceeding 100 pCi/g Given that only 10 percent of the NORM reported in survey responses exceeds this threshold, the annual figure must be multiplied by 10 to accurately reflect the true annual NORM accumulation rate.

APPENDIX A-SAMPLE OF NORM DISPOSAL

Contact Name Job Title Phone

Section 1 O NORM from Oil and Gas Production

Note: Ail dose rate readings in microRem/hr

(mWhr), including background) 1.1 Solid NORM Wastes in Storage (Scale and Sludge from Oil and Gas Production)

1.1.1 Solid Wastes (scale, sludges, etc.)

Other Solid Wastes (please describe) drums

Surface Dose Rates ( m m r ) Radium concentrations (pCigram) (if known)

Region (North N South S OCSlOffshore O) Percent

1.2 NORM Containing Tubular Goods in Storage (Tubulars, Sucker Rods, Flow Lines)

1.2.1 Total Length in Feet 15.000' 34' x 0.0315 drumdit = 14 drums

Approximate Percentage Distribution by Size Less than 2"

Radium concentrations (pcilgram) (if known) Suriace

1.3 NORM Containing Stored Vessels, Tanks,Treaters, Etc (Out-of-Service, In storage)

1.3.1 Approximate Number of Items Separators Treaters Tanks Other Estimated Total NORM Volume'

Radium Concentrations (pclgram) (if known)

1.3.2 Approximate Geographic Distribution of the Contaminated Equipment

State Region (See section 1.1.2) Percent

1.4 NORM Containing Processing Facilities Tank Batteries, Well Pads Estimated Volume of

Contaminated Soil (in Service and Out of Service on Location)

1.4.1 Estimated Number of Facilities Estimated Total NORM Vdume'

% > 1000 1.4.2 Approximate Geographic Distribution of Facilities

1.5 Estimated total Number of NORM Containing Items Generated in 1992

Estimated Total 740 drums 9,000 feet 4 number

'Further described in the instruction letter

A NATURALLY OCCURRING RADIOACTIVE MATERIAL DISPOCAL COST STUOV 17

Oil wells Gas wells Oil wells Gas wells

Number of wells in production Total Annual production for: (stale units used)

Region (See section 1 i 2) LA-OSCiOff s hore

1.7 Produced Water Ponds, Pits, Etc, (in Service) 1992 1.7.1 Number

Estimated Sludge Depth (ft) Average Years in Service Average Inflow üpd Percent Checked for NORM Percent of Pits Checked Found with NORM Estimated NORM Contents

Estimated Total Drums of NORM Containing Soil & Sludge

Comments: Above numbers do not include out-of-service pits

1.8 P K A (Plug and Abandonment) Program 1992 1993 (estimate)

Number of Wells P 8 A s with NORM Tubulars in Place Number of Wells P 8 A s Used for Disposal of NORM Solids Number of Drums NORM Disposed by P & A

State Region (See section 1.1.2) Percent

Section 2.0 NORM From Gas Plant Operations

2.1 Solid NORM Wastes in Storage (Gas Processing)

2.1.1 Lead-210 Scales and Sludge from Gas Processing Other Solid Wastes (please describe) drums drums

Lead-21 O Concentration (pCiGram) (if known)

Region (North N South S OCS/Offshore O)

2.2 NORM Containing Stored Vessels, Tanks, Equipment, Etc (Out-of-SeMce, In Storage)

Tanks Approximate Volume of NORM 2.2.1 Approximate Number of Items Pumps Filters Other

Lead-210 Concentration (pCúgram) (if known)

Region (North N South S OCS/Offshore O) Percent

2.3 NORM Containing Gas Processing Plants (in Service and Out-of-Service on Location)

2.3.1 Approximate Number of Facilities % Checked for NORM

Average Exterior Surface Dose Rates

Region (North N South S OCS/Offshore) Percent

2.4 Estimated NORM (Leaâ-210) Containing Items Generated in 1992

Soli Wastes Piping Equipment Other Accumulations

Estimated Total Drums Feet Number Drums

Section 3.0 NORM Disposal Job Program Costs

Job Description: Dispose of NORM Slurry in P & A wells typical job

($0000) andlor Cost as Percent of Total

3.2 NORM Program Regulatory Training Activities

Comments: 1991 and 1992 NORM training was conducted "in-house;" not able to trace costs 1993 training was conducted by

Note: Please photocopy this sheet and complete one of each typical job

APPENDIX B-SAMPLES OF NORM DISPOSAL JOB/PROGRAM COSTS

Section 3.0 NORM Disposal JobIProgram Costs

Breakdown of Services Included Decon Tubulars

Decon Equipment Decon Site NORM Transportation NORM Storage Company Disposal Downhole (P 8, A) Disposal On Site

Disposal Commercial Sample Analysis Other Add Description:

(80000) and/or Cost as Percent of Total

Section 3.0 NORM Disposal JobiProgram Costs

Job Description: Sand sludge generated offshore processed for reuse as landfill cover

($0000) andlor Cost as Percent of Total

A NATURALLY OCCURRING RADIOACTIVE MATERIAL DISPOSAL COST STUDY

Section 3.0 NORM Disposal JobíProgram Costs

Job Description: Shell production pad (¡.e Soil)

Breakdown of SeMces Included Decon Tubulars

Decon Equipment Decon Site NORM Transportation NORM Storage Company Disposal Downhole (P & A) Disposal On Site

Disposai Commercial Sample Analysis Other Add Description:

Work Done in Remote Location Housinq Per Diem

($0000) andior Cost as Percent of Total

Section 3.0 NORM Disposal Job/Program Costs

Job Description: Dispose of NORM slurry in P & A wells

($0000) and/or Cost as Percent of Total

Comments: 1991 and 1992 NORM training was conducted "in-house." Not able to trace costs 1993 training was conducted by consultants

Job Description: NORM scaleisludge disposal in P & A well

Decon Equipment Decon Site NORM Transportation NORM Storage Company Disposal Downhde (P & A) Disposal On Site

Disposal Commercial Sample Analysis Other Add Description:

($0000) andior Cost as Percent of Total

Job Description: Decontamination of production equipment, encapsulate in 7 5/8” casing, run into P & A well

($0000) and/or Cost as Percent of Total 2,800

Comments: These are actual cost for disposal job in 1993

Section 3.0 NORM Disposal JoblProgram Costs

Job Description: Decontamination of production equipment, slurry and pump down of NORM into P & A well

Decon Equipment Decon Site NORM Transportation NORM Storage Company Disposal Downhole (P b A)

Disposal On Site Disposal Commercial Sample Analysis Other Add Description:

($0000) and/or Cost as Percent of Total

Comments: This is the actual job done in 1992 The slurry and pump was performed on the offshore platform

APPENDIX C-NORM DISPOSAL COST STUDY QUESTIONNAIRE REPLIES

The article discusses the average oil production rates, specifically focusing on condensate and the estimated average rates per hour for various facilities It highlights the reference drums and their corresponding dose rates, providing a comprehensive overview of the production metrics in barrels per day (BPD) for both pits and drums.

Training Calculated Reference WellDrums Facilities Drums Description Drums (OOO$) 91 92 93 perDnim

Reply P & A Wells Checked # Est Summary Cost (0008) cost

A NATURALLY OCCURRING RADIOACTIVE MATERIAL DISPOSAL COST STuw 31

Reply Avg uWh Drums Avg uR/h Est Avg u R h Facilities/ Avg uR/h Forecast Oil Prod Condensate

Referencc Drums Dose Rates Equiv Dose Rates Drums Dose Rates ûNms Dose Rates Drums 000BPD 000BPD PitslDnims

Refeirnce WelüDrums Facilities Drums Description Drums (OOO5) 91 92 93 $/Drum Drums

Reply P & A Wells Checked# Est Summary cost (000%) cost

137 010 O O Clean 550 2 5 o o o O Many Similar 1.8íM.OOO

Reply Avg uRlh Drums Avg uWh Est¡ Avg uR/h Facilitiesl Avg um Forecast Oil Prod Condensate

Reference Drums Dose Rates Equiv Dose Rates Drums Dose Rates DNBS Dose Rates Drums 000BPD O00 BPD PitslDrums

Training Calculated Reply P & A Wells Checked # Estimate Summary cost (OOoS) cost

Reference WelllDnims Facilities DNBS Description Drums (OOO$) 91 92 93 $ / i h m

APPENDIX D-TRANSPORTATION COST MATRIX BY REGION

Permitted Disposal Location i Richland Washington

5 Nearest Major Port (or Houston)

6 Nearest Major Port (or Houston) 7,8,9 Local Well Nearest Suitable Well

Transport Cost Estimates per Drum

Burial Burial Treat Spread Injection China Recycle Russia Encapsulation Plug & Abandon or Injection

O 30 35 40 20 20 O aTranspon included in rates bVolume on a full load and exclusive use truck

APPENDIX E-ACTUAL DISPOSAL COSTS (PER DRUM) FOR PLUG AND

All Cost Data From Region 1

APPENDIX G-NORM ACCUMULATION BY TYPE OF SOURCE

No of Wells Drums of NORM

Reply No Solids Tubulars Equipment and Sites Oil C S

Tiêu đề	A Naturally Occurring Radioactive Material (NORM) Disposal Cost Study
Tác giả	American Petroleum Institute
Trường học	American Petroleum Institute
Chuyên ngành	Exploration and Production
Thể loại	Publication
Năm xuất bản	1996
Thành phố	Washington, D.C.

Định dạng
Số trang	44
Dung lượng	1,57 MB