Norm and Tenorm

NORM / TENORM in Oil & Gas and Rare Earth Industries

USEPA ORIA - TENORM Associated with Unconventional Oil and Gas Production and Rare Earth Mineral Extraction and Processing

Mr. Brown served as the Sandy Cohen and Associates Task Manager for two projects for the US EPA Office of Radiation and Indoor Air to update current state of knowledge regards to occurrences and potential radiological impacts of NORM ./ TENORM radionuclides associated with (1) recently expanding “unconventional” sources and recovery methods in the oil and gas industry and (2) related to the rare earth minerals and the regulatory challenges associated with the environmental, public and worker exposures. Draft updated reports for each were the products of these tasks and are under internal EPA review as of the time of this writing (early 2024).

The O & G report identified the information available to construct a comprehensive view of TENORM associated with unconventional oil and gas activities – generation, characteristics, management, and potential for environmental impacts and human exposure. It included TENORM associated with drilling and production in conventional (permeable) reservoirs, and unconventional drilling and production from low-permeability shale, tight sandstone, and tight limestone host rock formations. The report also evaluated publicly available literature to identify information on the potential pathways and magnitude of radiation exposures that are being documented now and are likely to be seen in the foreseeable future because of the growth of this industry.

The purpose of the RE report was to summarize and evaluate the scientific literature for information related to rare earth minerals and their associated TENORM. The report included information obtained on the geological and geochemical occurrence and radiochemistry of the rare earth elements and detailed the uses of RE minerals, their environmental radiological fate and transport, and their wastes. Current knowledge of thorium and uranium dosimetry and the regulatory challenges associated with the environmental, public and worker exposures, and estimates of those doses and risks were evaluated.

Licensing and Radiation Safety Officer for Rare Earth Mineral R & D Laboratory

Since 2022, Mr. Brown has been assisting a large Rare Earth (RE) mining project developer on radiological matters related to their RE mineral processing development laboratory in the Denver metropolitan area. This facility receives RE ore samples from their mine site in Texas for research and development of optimal extraction and processing technologies. As is common with RE deposits globally, the naturally occurring uranium and/or thorium isotopes and progeny often mineralize co-located with the RE minerals. During processing, the U/Th can become concentrated into levels that constitute licensable source material. Accordingly, under State of Colorado regulations, a radioactive material license and associated radiation safety program is required. Since preparing the initial license application and subsequent issuance, Mr. Brown has served as the State approved Radiation Safety Officer (RSO) under this license. His responsibilities as the RSO have included providing initial and subsequent annual refresher radiation safety training to plant operators, design and oversight of radiological surveys, worker dosimetry and public / environmental monitoring programs and preparing and maintaining agency approved radiological survey and licensed material management procedures.

A man standing in front of a cloud with arrows pointing to the ground.

Management of NORM in Other Industrial Applications

Acceptance of NORM (TENORM) at Industrial Landfills, Colorado - Two large, national industrial landfill operators requested the State of Colorado for permission to accept industrial wastes containing NORM and/or TENORM (uranium, radium e.g.) up to the limits allowable under Colorado regulations for industrial landfills (≤ 50 pCi / gram radium; ≤ 0.05 % natural uranium by weight). Mr. Brown assisted the operators in responding to a number of technical questions the State required to be addressed related to worker and public radiological risks that could be associated with acceptance of this material by the landfills. These projects included modeling of the radiological doses to workers and the public using the RESRAD and MILDOS computer codes (Argonne National Laboratory) and preparing Waste Acceptance Criteria (WAC) and associated procedures for acceptance and disposal of radiologically contaminated industrial waste streams. These assessments included developing dose estimates for a worker at the facility, located directly on top of the contaminated materials at the site and a nearby resident, potentially exposed to radon in air that is released from the landfill.

A chart showing the activity concentration of various substances.

A man standing next to a pipe with an orange hose attached.

A diagram of the earth 's crust and the ground.

Two men in white suits working on a pipeline.

Colorado Oil and Gas Association

As radiological consultant to the Colorado Oil and Gas Association (COGA), provided assistance in a number of technical areas related to the development of TENORM regulations in Colorado. Have prepared COGA’s comments on the States’ TENORM studies and draft guidance, reviewed large radiological data basis to evaluate TENORM content of a number of O & G waste streams to assess potential candidacy as regulated material under the evolving regulations. Also have been evaluating various standard analytical methods being used for detection of TENORM nuclides (U, Th, Ra, Po, Pb) from perspective of accuracy, precision, and for minimizing analytical costs and turnaround times.

Licensing and Radiation Safety Officer for Municipal Water Districts, Colorado

Licensing and Radiation Safety Officer for Municipal Water Districts, Colorado - Since 2010, Mr. Brown has been assisting three Municipal Water Districts in Colorado on radiological matters related to their raw water treatment systems that provide all domestic water to many thousands of homes. The water treatment residuals produced contain elevated levels of NORM radionuclides (uranium and/or radium) and are considered “licensed material“ under State of Colorado regulations requiring a radioactive material license and associated radiation safety programs. Since preparing the initial license applications and subsequent issuance, Mr. Brown has served as the State approved Radiation Safety Officer (RSO) under these licenses. His responsibilities as the RSO have included providing initial and subsequent annual refresher radiation safety training to plant operators, design and oversight of radiological surveys, worker dosimetry and public / environmental monitoring programs and preparing and maintaining State regulatory agency approved radiological survey and licensed material management procedures.

Radiological Surveys at Municipal Water District Treatment Plants

Designed and executed radiological surveys to assess potential for worker radiation exposure from NORM / TENORM materials for two large Denver area municipal water districts serving hundreds of thousands of users. These projects involved conduct of radiological surveys in seven water treatment plants to determine real-time gamma exposure rates and use of longer-term radon (track – etch) and gamma dosimeters (OSLs) placed throughout the facilities for approximately 30-day periods. This comprehensive radiological monitoring program demonstrated that the radiation exposure to workers appeared to be consistent with natural background radiation exposure in Colorado.

Dose Assessment for Solids Waste Processing Facility

Completed a worker dose assessment for a solid waste processing facility in Colorado that receives a variety of wastes from oil and gas exploration and production activities. Because of the potential for TENORM wastes being received, the State regulator requested the operator to conduct a human health risk assessment (dose assessment) for the facility. The assessment was based on the assumption that 50 picocuries per gram of naturally occurring radium 226 (Ra-226) would be present in all solid waste materials processed and temporarily stored within these facilities. The potential for both external radiation exposure (via exposure to gamma rays) and internal exposure (via inhalation of dusts and radon gas) were both evaluated in this assessment.

Radiation Safety Officer for Licensed Water Treatment Plant

From 2019 - 2022, had been the Radiation Safety Officer for a water treatment plant in Winter Park, Colorado. This plant treats natural waters that drain from the Moffat (Railroad) Tunnel. The water must be treated prior to release to the Frazer River. As a result of the treatment process, a waste cake sludge is produced that contains greater than 1000 ppm natural uranium and is, therefore, licensed source material under the US Atomic Energy Act. The plant is licensed by the Colorado Department of Public Health and Environment.

SHB Inc.

Norm and Tenorm

NORM / TENORM in Oil & Gas and Rare Earth Industries

Management of NORM in Other Industrial Applications

SHB Inc.