NORM and TENORM -- Are We Heading For a New Legal Normal?

Abstract

A by-product of oil production is naturally-occurring radioactive material (“NORM”), and its disposal in connection with primary recovery has historically not been unduly problematic for the oil industry. With secondary recovery projects such as waterfloods, the recirculation of water can enhance the level of radioactive material creating technologically enhanced radioactive material (“TENORM”). The same effect can be created with hydraulic fracturing and recycling of wastewater. The widespread use of hydraulic fracturing, and the resultant public concern about it, has brought NORM and TENORM to the forefront of the public consciousness.

That new awareness of the existence and necessary disposal of NORM and TENORM has spawned a host regulatory and legal actions related to its proper handling and disposal. This presentation would discuss generally the regulatory frameworks currently in place in the states comprising the Eastern Section. It would also review the trends of proposed changes in regulations and the state and federal litigation that may be driving some of those proposals. Finally, it will discuss the impact some of the proposed changes may have on oil and gas operations and waste disposal activities.

AAPG Datapages/Search and Discovery Article #90258 © 2016 AAPG Eastern Section Meeting, Lexington, Kentucky, September 25-27, 2016