Technologically-Enhanced Naturally-Occurring Radioactive Material
North Dakota is currently the only oil-producing state that does not have a disposal site for this waste material produced in the oil and gas drilling and production process. However, Williams County recently approved conditional use permits for two companies seeking to dispose of TENORM in existing landfills. Secure and Energy and WISCO Inc. must also obtain a radioactive materials license from the Department of Environmental Quality before operations can begin.
TENORM is found in drill cuttings, filter socks, produced water, tank sludge, pipe scale, etc. There are other common items that contain similar low levels of radioactivity such as smoke detectors, cat litter, bananas, coffee grounds and granite counter tops. Industrial processes concentrate the natural radioactivity in the material to a level that exceeds thresholds that require special handling and disposal. Other industries also create TENORM such as water and wastewater treatment plants, mining activities, medical facilities and fertilizer manufacturing.
TENORM is regulated by the state Department of Environmental Quality (DEQ), which requires reporting of trucks hauling the material and where it is destined for disposal. Shippers have to be licensed by the DEQ, and report what and where they’re hauling. The state produces an average of 92,000 tons of TENORM per year, all of which is now shipped out of state for disposal. If a landfill is developed for the disposal of TENORM in North Dakota, it would be permitted and monitored by DEQ.
WDEA commissioned a research effort to determine the best options for disposal in the state. The study produced a heat map to show likely locations of future drilling activity, which are the areas where TENORM is expected to be produced in the coming years. The study is intended to allow the state to be responsible for handling most or all of the waste it generates, to prevent the industry’s vulnerability to the chance that another state may one day refuse to accept TENORM from North Dakota. Around 90 percent of the TENORM is now going to Montana, about eight percent to Idaho, and smaller amounts to Colorado and Oregon.
States have varying limits on the level of radioactivity they will accept for disposal. Colorado’s level is 2,000 picocuries/gram, while Montana was at 200 and recently changed to 50. North Dakota also has a 50 picocuries/gram limit, and allow 25,000 tons per site per year, and no more than 3,000 tons per month.
Slurry wells are another disposal option. TENORM must be first pulverized into very fine particles and then mixed with produced water from drilling operations to form a slurry, which is injected into an underground formation by a disposal well. Three such wells have been permitted in North Dakota, but only one is currently operating. The facility, owned by KT Enterprises, began injecting slurry in April at a site near Johnsons Corner in McKenzie County.
The WDEA study led to establishment of a working group to develop recommendations for siting, permitting and monitoring of TENORM disposal operations. The group was made up of legislators, county representatives, industry experts and regulators from DEQ and the Department of Mineral Resources.
Click here for the DEQ’s database of information related to TENORM.
Issue Updates7/23/21 - Williams Co. Plans TENORM Hearing
7/2/21 - Williams County Okays TENORM Sites for Two Landfills to Handle Oil Industry Waste
6/25/21 - Williams County to Consider TENORM Apps
6/18/21 - TENORM Disposal Projects Stalled: Next Steps to Occur at June 29 Meeting
6/18/21 - TENORM Slurry Well in Operation: Facility Has Injected 9,000 Barrels
5/28/21 - WDEA to Host June 16 TENORM Meeting: Info on Pending Williams County Applications
7/24/20 - WDEA board hears TENORM report; Consolidated landfill siting recommended
1/4/20 - WDEA to Develop TENORM Study
12/20/19 - WDEA Will Consider TENORM Study
Resources and References
ND Dept of Environmental Quality - TENORM Information
Resources page of the ND Department of Environmental Quality which contains links to dozens of items, including a description of TENORM rules and regulations in other states.
TENORM Disposal in North Dakota Landfills
Argonne National Laboratory
Frequently Asked Questions about TENORM
WDEA prepared a fact sheet on the most commonly asked questions. The FAQ was distributed at a public information meeting in Williston on June 16, 2021.
Summary of Argonne Laboratory TENORM Study
The North Dakota Department of Health commissioned Argonne National Laboratory to determine landfill radiation limits that would be safe for workers and the public. NDDoH provided information on oilfield-related Technologically Enhanced Naturally Occurring Radioactive Material, or TENORM, including scale that forms on pipe and equipment, sludge, filter socks and proppant (synthetic sand).
Argonne study performed for North Dakota DEQ.
Full text of the 140-page study.