API PUBL 7100:1996

FOREWORD This publication is based on oil and gas company questionnaires representing naturally occurring radioactive materials (NORM) accumulated to the end of 1992 and annually produced during 1993, along with some replies from 1994 also added. The production of oil and gas in the United States has resulted in the formation of scales and sludges containing NORM. This study is based on the actual costs of NORM disposal obtained through questionnaire replies from oil and gas producers. The NORM questionnaire replies were received from companies representing 46 percent of the domestic U.S. oil, gas, and gas condensate production. The survey results were prorated to represent 100 percent of the U.S. oil and gas industry. Most of the oil and gas producing states of the U.S. are represented in the survey replies. This document details the reported quantities of NORM that have accumulated over the years and the annual rate of NORM production for 1993 from the domestic U.S. oil and gas condensate production. No data was received for NORM in the gas industry. This publication documents the 1992 costs of the available NORM disposal options at that time and calculates the cost impact of disposing of the accumulated NORM and the annual cost of compliance with existing and proposed NORM regulations. Over a number of years, it is estimated that on a volume basis some 10 million drums (55 gallons each) of NORM have accumulated in widely scattered pieces of production and process equipment, produced water ponds, and treatment pits. Of this accumulation, some percentage has been processed and disposed of by routine industry disposal practices. For instance, NORM-containing scrap steel such as old production tubulars were routinely recycled by the steel scrap industry, until that industry installed radiation detectors that screened steel scrap for radiation sources. The detectors became widely used in the late 1980's. Consequently, NORM-containing scrap steel recycled before the use of radiation detectors is no longer part of the waste stream. Similarly, some percentage of NORM-containing E&P waste may have undergone treatment such as land farming in which the concentration of NORM in the waste material is no longer distinguishable from background levels. Nevertheless, the 10 million drum accumulation figure is conservative and provides some margin for possible underreporting. Survey monitoring programs to detect and quantify NORM are in operation in virtually all domestic U.S. oil and gas producing areas. These programs are designed to provide NORM data to satisfy regulatory reporting requirements. The questionnaire replies include two reports of very large NORM accumulations. These two reports, along with a concentration of reported NORM data from the Gulf Coast of Louisiana and Texas, were included in the database used to extrapolate the reported NORM quantities to represent the entire U.S. oil and gas condensate production industry. However, recent reports of NORM in the feed stocks to the downstream refining and processing industry that are not included in this report may indicate an underreporting of the annual NORM accumulation rate of 140,000 drums per year. Other studies [1.2] have indicated that this annual figure could be four times higher than reported in the questionnaire replies, even after prorating to represent the entire industry. There are a growing number of NORM disposal options defined by the specific activity of the NORM that they will accept, all of which are licensed or permitted by federal and state agencies. The NORM acceptance criteria are different for each disposal site, as are the disposal costs. The range of available NORM disposal options at the end of 1993 include the following: -- Burial sites. -- Surface treatment. -- Commercial injection disposal. -- Recycling of steel. -- NORM recycling into shielding bricks. -- Plug and abandonment of wells, encapsulation and injection. Disposal costs per drum of NORM vary depending on the specific activity of the scale, the number of drums, and the disposal option selected. Costs range from approximately $74 minimum to $3333 per drum. Actual average costs to date reported in the NORM questionnaire from the U.S. domestic oil and gas industry are $544 per drum with a maximum of $20,000 per drum reported by more than one company. Using the average disposal cost per drum of $544, the annual cost impact of disposing of the 142,000 drums of accumulated NORM would be $77 million per year. The potential cleanup over 25 years of the accumulated NORM volume of 10,000,000 drums at 400,000 drums per year adds an additional cost of $218 million per year. The total annual NORM disposal cost could be $295 million per year for the next 25 years. These figures do not include the costs to identify, sample, analyze, clean, and contain the NORM ready for disposal. NORM disposal costs may be reduced significantly if one or more of the following options are used: -- Volume discounts offered by the disposal companies. -- Cheaper disposal options becoming an operational reality. -- Disposal volume reduction due to regulatory compliance matched to real risk. -- Exempt concentration level above 30 picoCuries per gram (pCi/g). Other disposal options may have been introduced since the date of this survey in 1992-93. They are not evaluated in this publication. API publications may be used by anyone desiring to do so. Every effort has been made by the Institute to assure the accuracy and reliability of the data contained in them; however, the Institute makes no representation, warranty, or guarantee in connection with this publication and hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal regulation with which this publication may conflict. Suggested revisions are invited and should be submitted to the director of the Exploration and Production Department, American Petroleum Institute, 1220 L Street, N.W., Washington, D.C. 20005.