MacDOWELL, PETER, and PETER GRAY, Greenfield Environmental, Anaheim, CA

ABSTRACT: Naturally Occurring Radioactive Materials: Projected Financial and Fiduciary Impacts on E&P Operations with Contaminated Drilling Equipment, and Soil

The oil industry's awareness of naturally occurring radioactive materials (NORM) as an inherent waste in E&P operations is decades old. However, recent regulatory focus in Louisiana, Mississippi and EPA Region IV requiring risk management procedures for handling NORM-contaminated equipment, soils, and discharged water suggest growing regulatory concern which could significantly influence E&P operations. Additionally, emerging legal action, regarding property damage resulting from the presence of NORM, will most certainly compound the financial and fiduciary impact of this once overlooked risk. Given the growing national regulatory interest and high-profile legal actions regarding NORM, a ripple effect, through the other 27 oil and gas producing states and the EPA, can be expec ed.

The authors will review the history of awareness of NORM in the oil industry and present examples of existing E&P companies operational procedures for handling this material. Discussion of the status of individual state and federal agencies efforts regarding NORM will also be presented. The environmental risks associated with drilling and production pipe rehabilitation and storage will be evaluated, as will existing technologies for material handling, disposal, and NORM waste reduction. Financial and fiduciary ramifications of various regulatory scenarios will be presented.

AAPG Search and Discovery Article #90992©1993 AAPG Pacific Section Meeting, Long Beach, California, May 5-7, 1993.