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Re: oil and gas industry compliance assistance

Hi Nancy,

I hope this message finds you well.

Have you heard of TENORM - Technologically Enhanced Naturally Occurring
Radioactive Materials? Loren Setlow of EPA gave the talk summarized
below at EPA's August, 2003 Emerging Pollutants Conference in Chicago. I
don't know what the P2 solutions are, but TENORM, and its prevention,
should be a part of the discussions with your partners. Loren Setlow can
probably help you. Her telephone number is (202) 343-9445.

For more info. on the Emerging Pollutants conference, see:

Good Luck!

U.S. Environmental Protection Agency
Region/ORD Workshop on Emerging Pollutants August 11-14, 2003

Radium in Oil and Gas Piping and Production Facilities
Loren Setlow, U.S. EPA Office of Radiation and Indoor Air (ORIA)
Radium is toxic and a potent carcinogen. Health problems associated with
it were first
discovered among the women who used radium to paint watch dials and
faces. A high incidence
of cancer of the mouth was found among these women, who would place
paint brushes in their
mouths to create a point in the bristles between applications of radium
paint. Radium degrades
to cause radon and other radionuclides and is present naturally in soil
and water throughout the
The presentation covered the problem of radiation in oil and gas
production facilities and in
other industrial processes. Radiation at oil and gas facilities is not
normally evaluated during
environmental site investigations and cleanups. Such sources of
radiation may pose potential
health and safety hazards to inspection personnel and to the public.
Because of recycling of
radioactive piping and other materials from oil and gas production
facilities, radiation is present
in many unexpected residential and industrial settings.
Technologically Enhanced Naturally Occurring Radioactive Materials
(TENORM) are materials
containing radionuclides that are present naturally in rocks, soils,
water, and minerals and whose
radioactivity has become concentrated and/or exposed to the accessible
environment as a result
of human activities.
Because of concerns about TENORM, a Regional EPA Guidance, “Potential
for Radiation
Contamination Associated with Resource Extraction Industries,” was
issued on April 15, 2003 to
EPA Regional radiation personnel, regional Superfund staff, the National
Hardrock Mining
Team, and On-scene Coordinators. This guidance informs EPA staff of
radiation associated with
specific minerals resource extraction, processing, or manufacturing
industries. The guidance
will help EPA field staff to contact key EPA regional radiation staff
personnel to implement
radiation safety measures and conduct radiation surveys, as appropriate.
The guidance can be
found at www.epa.gov/radiation/tenorm/about.htm.

Some industries with TENORM contamination include the following:
aluminum (bauxite),
copper, fluorspar, gypsum, molybdenum, phosphate, phosphorus, potassium
(potash), precious
metals (gold, silver), rare earths including monazite, tin, titanium
(leucoxene, ilmenite, and
rutile), tungsten, vanadium, zircon, coal (and coal ash), oil and gas,
and geothermal energy.
Water and sewage treatment facilities also can be contaminated with
In regard to oil and gas facility TENORM, radium levels can range from
non-detectable to more
than 100,000 picoCuries/gram. Five picoCuries is the allowable limit for
radium in pipe scale.
It should be noted that radium is much more dangerous than uranium or
thorium ore. In 1996,
the American Petroleum Institute (API) estimated that the equivalent of
30,000 m3 of TENORM
was generated in 1993. This same study, using radiation survey data,
estimated that there is the
equivalent of 3.4 million m3 in total legacy inventory. In some cases,
TENORM has gotten into
facilities that recycle steel. Such facilities have had to install
radiation monitors to reject
radioactive materials. Some contaminated pipe has been used in homes and
In regard to TENORM in Region 5 oil and gas facilities, oil field
equipment with 5,000
microR/hr was found at one Michigan pipe yard. An API study found that
92% of production
facilities in Illinois had radiation contamination.
Radium is selectively soluble in underground formations and is mobilized
in production waters
in preference to uranium and thorium. The radium precipitates out at the
surface because of
changes in temperature and pressures compared to underground conditions
and it plates the
interior of pipes, separators, storage tanks, gas lines, etc. On the
basis of a 1989 API report and
other studies, it is believed that one-third of all producing U.S. oil
and gas wells have elevated
The first oil wells were drilled in the 1860s. According to the Illinois
State Geological Survey,
155,000 wells have been drilled in the Illinois basin alone. A hot trend
now is to drill natural gas
wells into coal beds to recover coal bed methane. Because coal contains
TENORM can be generated. Contaminated water also is a problem that must
be managed.
There is a problem managing TENORM contaminated water in the Powder
River Basin coal
fields because a lot of water is produced.
By anecdote, Setlow has heard that scrap yards have been under orders to
not accept oil field
pipe, and there have been some problems in the automotive industry from
radioactive metal used
in cars. Contaminated metal made from scrap has been used in many
places, including
playgrounds. Exposure to TENORM in pipe scale has been a problem for
pipeyard workers.
Until the 1990s, workers at pipeyards used to knock the scale out using
hammers; now, chemical
and hydraulic pressure means are used.
Exposure to the scale and disposal of the TENORM-contaminated scale is
an issue. When
radium is in the mineral scale, it is locked up in the mineral matrix
and not readily leachable.
But when it is broken out of the pipe or tanks or other vessels and
ground up, it becomes an
inhalation hazard and a toxin that gets into the ground.
TENORM also can contaminate soil. The MCL for Radium-226 in soil is 5
At one site in Michigan, soil samples contained up to 2700
U.S. Environmental Protection Agency
Region/ORD Workshop on Emerging Pollutants August 11-14, 2003
Oil and gas TENORM waste disposal methods include injecting wastes into
the original
producing formation, deep injection well disposal, disposal at licensed
facilities, land and road
spreading, and re-use and recycling of equipment. TENORM cannot be sent
to RCRA Subtitle
C or D landfills (except under some special cases). It usually has to be
disposed of at a facility
for low level radioactive wastes.
There have been more than 5 million oil wells drilled in the U.S. and
any of them may have
TENORM that may never have been dealt with or even recognized. Modern
protection methods didn’t commence until the 1970s. Pre-1970s legacy
wastes may remain at
sites that could be converted to home and building sites. As residential
communities move into
former oil and gas production areas, the need to identify and address
TENORM becomes
increasingly important.
As already mentioned, potential hazards exist from TENORM contaminated
recycled metal
scrap, mineral scale, and pipes. In one case in New Orleans, 26 acres of
land was leased to a
pipe yard. The pipeyard company did not clean up the radium scale on the
property, and the
owner of the land sued the pipeyard company and the oil companies which
supplied the pipe to
be cleaned. In 2001, a $1 billion judgment was handed down in the case
for both compensatory
and punitive damages. The workers at the pipe yard were exposed to
radiation while they broke
the scale out of the pipes and several of them subsequently sued their
employer saying they were
never told of the risks associated with this activity.
In regard to TENORM contamination associated with current production
sites, RCRA may not
apply, but other U.S. EPA authorities are available (CERCLA, CWA, SDWA,
and TSCA).
Petroleum industry associations, individual companies, and some states
have developed
guidances for handling TENORM. EPA ORIA is investigating ways to partner
with industry
and other stakeholders to address this issue.
More research is needed on the occurrence of legacy oil and gas radium
wastes and current
operational and disposal practices. This research is needed to reduce
potential for public,
professional, and worker radiation exposures.
Comments/Questions and Answers
Q – What levels of radiation can be found in the pipe scale?
A – The scale can have levels of hundreds of picoCuries/gram. Scrap
metal companies are
supposed to have zero tolerance for radioactivity.
Q – Do the automobile manufacturers look for radioactivity in the metal
they receive?
A – Don’t know.
Q – Why don’t scrap companies use Geiger counters?
U.S. Environmental Protection Agency
Region/ORD Workshop on Emerging Pollutants August 11-14, 2003
A – It depends on the company. Not all train their workers on how to
deal with pipe scale.
Q – What is the level of exposure to radiation to workers in oil fields?
Are there any effects?
A – Don’t have data on this. OSHA has standards. OSHA and the Nuclear
Commission say occupational exposures can be five times the level of
exposure allowed for the
Q – Is radon a degradation product of radium?
A – Yes. In many cases radon emissions become the driver of risk
assessments that are
performed. Radium dust contaminates soil. It is a problem if
contaminated soil is used for a
playground. Radiation also can occur if a house is built over a
contaminated site.
Q – Are there any pollution prevention remedies to this problem, like
using water softeners?
A – Some producers use scale inhibitors, but this just moves the problem
further down the line
toward the refineries.
Comment – Institutional controls could limit it.
A – At this point, 37 states have oil or gas wells, but only 10 states
have regulations for
TENORM. The issue is whether there are controls built into the
production process.
Q – Is radium leachable into the new steel in which the scrap is
A – Some of the radium goes into the slag, some of it goes into the
steel. The percentages
depend on the smelting temperature.
Q – Have you found radioactivity in the natural gas used to burn in our
homes? Is it then air
A – Some has been found in gas lines, but it isn’t a risk in most homes.
The radium goes into
the air when the gas is burned.
Q – Is lead 210 a scale that develops?
A – Yes, it is deposited over time.
Q – Is radium a problem in drilling mud?
A – It can be. It can also be a problem in produced water. Producers try
to recycle the drilling
muds. There are pits (including dried out pits) containing produced muds
and water all over the


Leif Magnuson
Pollution Prevention Coordinator
U.S. EPA Region IX, WST-7
75 Hawthorne St.
San Francisco, CA  94105
(415) 972-3286 Tel
(415) 947-3530 Fax

                      Nancy Larson                                                                            
                      <nlarson@ksu.edu>        To:       p2-tech <p2tech@great-lakes.net>                     
                      Sent by:                 cc:                                                            
                      owner-p2tech@grea        Subject:  oil and gas industry compliance assistance           
                      03/16/2004 01:03                                                                        
                      Please respond to                                                                       
                      Nancy Larson                                                                            

We are initiating a compliance assistance outreach program with the
Kansas independent oil and gas association and wondered what other
states have done something similar in the past?  To begin with we will
work with them on air emission issues (extraction engine emissions), but
need to research other compliance issues, as well as identify any
industry specific tools.

If you can help, please contact Nancy directly at nlarson@ksu.edu.


Nancy J. Larson, RS
Industrial Pollution Prevention Specialist
KSU Pollution Prevention Institute
7001 West 21st Street North
Wichita, KS 67205
316/722-7721 ext. 104

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