Naturally Occurring Radioactive Material (NORM) is present in subsurface formations and is brought to the surface during oil and gas production. When human activities concentrate these radionuclides — primarily radium-226 and radium-228 — above natural background levels, the material becomes Technologically Enhanced NORM (TENORM). TENORM accumulates in pipe scale, sludge, produced water, and on equipment surfaces throughout the production stream. There are no comprehensive federal regulations governing NORM/TENORM in the oil and gas industry; instead, regulation falls primarily to individual states. Key regulatory states include Texas (Railroad Commission Subchapter F and DSHS Title 25 TAC Chapter 289), Louisiana (LAC 33:XV), North Dakota (NDAC 33-10-20), and others with active programs based on the CRCPD Part N model regulations. Regardless of which state applies, a NORM compliance program must address worker exposure monitoring, radiation surveys, waste characterization, equipment labeling, proper disposal, decontamination, training, and recordkeeping. This checklist covers the common elements required across state programs.
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State-Specific NORM/TENORM Regulations
NORM/TENORM in oil and gas is regulated at the state level. Key states include: Texas (16 TAC §4.601-4.630 for RRC disposal; 25 TAC §289 for DSHS possession/use/transport), Louisiana (LAC 33:XV — Radiation Protection), North Dakota (NDAC 33-10-20), Mississippi (Mississippi Administrative Code Title 15 Part 3), and Pennsylvania (25 Pa. Code Chapter 287). Many states base their regulations on the CRCPD Part N model regulations for TENORM.
OSHA Ionizing Radiation Standards
OSHA’s ionizing radiation standard (29 CFR 1910.1096) establishes occupational dose limits of 5 rem (50 mSv) total effective dose equivalent per year. While not NORM-specific, this standard applies to worker exposure from all ionizing radiation sources including NORM/TENORM encountered in oil and gas operations. Employers must monitor exposure, post radiation areas, and maintain exposure records.
DOT Hazardous Materials Transportation
NORM/TENORM waste that exceeds DOT’s 70 Bq/g (2 nCi/g) activity threshold for radioactive material classification requires transportation as a Class 7 radioactive material under 49 CFR 173 Subpart I. Proper packaging, labeling, placarding, and shipping papers are required.
CRCPD Part N Model Regulations
The Conference of Radiation Control Program Directors (CRCPD) developed Part N of the Suggested State Regulations for Control of Radiation as a model for states to regulate TENORM. Part N covers licensing, worker protection, waste characterization, disposal, release criteria, and recordkeeping. Many state NORM programs are derived from or consistent with Part N.
NORM Program Documentation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Written NORM management plan | Written NORM/TENORM management plan or radiation protection plan exists covering: program scope, responsible personnel, survey protocols, worker protection measures, waste handling and disposal procedures, equipment labeling requirements, decontamination procedures, and training requirements. Plan is reviewed and updated periodically. |
| State regulatory identification | All applicable state NORM/TENORM regulations have been identified for each state where the company operates. Licensing or registration requirements are understood and fulfilled. State-specific disposal limits, exemption levels, and reporting requirements are documented and communicated to field personnel. |
| Roles and responsibilities | Radiation Safety Officer (RSO) or designated NORM coordinator is assigned with defined responsibilities. RSO qualifications meet state requirements. Organizational chart shows NORM program reporting structure. Contact information for state radiation control agencies is readily available. |
Radiation Surveys and Monitoring
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Baseline and periodic surveys | Baseline NORM surveys have been conducted on production equipment, piping, vessels, and facilities. Periodic resurveys are scheduled at frequencies consistent with state requirements and operational changes. Survey results are documented with date, surveyor, instrument used, background readings, and contact readings for each item surveyed. |
| Survey instrumentation | Radiation survey instruments are appropriate for detecting NORM (gamma detectors capable of measuring low-energy gamma from Ra-226/228). Instruments are calibrated per manufacturer specifications and at intervals required by state regulations (typically annually). Calibration certificates are current and on file. |
| Survey documentation and mapping | Survey results are mapped or tabulated showing radiation levels at specific locations on equipment and facilities. Results are compared to state-specific action levels and background readings. Equipment and areas exceeding action levels are identified for further characterization, labeling, or remediation. |
| Worker exposure monitoring | Personnel who routinely handle NORM-contaminated materials or work in areas with elevated radiation levels are monitored for exposure. Dosimetry (TLD badges or equivalent) is provided where required by state regulations or where exposures may approach occupational limits. Exposure records are maintained per OSHA 29 CFR 1910.1096 and state requirements. |
Waste Characterization and Disposal
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Waste characterization | NORM/TENORM waste streams are characterized by laboratory analysis for radium-226, radium-228, and other applicable radionuclides. Characterization includes concentration (pCi/g), volume/mass, and waste matrix (scale, sludge, soil, produced water, filter media). Characterization data supports proper disposal pathway determination. |
| Disposal pathway compliance | NORM/TENORM waste is disposed of using methods approved by the applicable state: injection into permitted Class II wells, burial on-site in plugged and abandoned wells, disposal at licensed NORM disposal facilities, or landfill disposal where state-specific concentration limits allow. Disposal manifests and receipts are maintained. |
| Produced water management | Produced water containing NORM is managed per state requirements. Radium concentrations in produced water are known. Disposal by injection, treatment, or other approved methods is documented. Surface discharge of NORM-containing produced water is prohibited or conducted only under specific permit conditions. |
| Prohibited disposal methods | Prohibited disposal methods are understood and communicated: road spreading of NORM waste is prohibited in most states, uncontrolled surface disposal is prohibited, and dilution for the purpose of meeting disposal limits is prohibited. No evidence of improper disposal practices exists. |
Equipment Management and Decontamination
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Equipment labeling and tagging | NORM-contaminated equipment is identified with clearly visible waterproof tags or markings reading “NORM” (plus translations where non-English-speaking workers are present). Tags include the date identified and contact radiation level. Labeling is maintained when equipment is moved, stored, or transferred. |
| Equipment release criteria | Decontaminated equipment meets state-specific release criteria for unrestricted use before being returned to service, sold, or scrapped. Release surveys are conducted and documented. Equipment that cannot be decontaminated to release levels is managed as NORM-contaminated material. |
| Decontamination procedures | Decontamination of NORM-contaminated equipment is performed by or under the supervision of personnel licensed by the state radiation control agency (e.g., DSHS specific licensee in Texas). Decontamination waste (wash water, removed scale) is characterized and disposed of properly. Decontamination records are maintained. |
| Scrap metal and recycling controls | NORM-contaminated equipment is not released for scrap or recycling without proper decontamination and release survey. Scrap metal loads are surveyed for NORM before release to recycling facilities. Documentation of NORM-free status accompanies released equipment. |
Worker Protection and Training
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| ALARA program implementation | An ALARA (As Low As Reasonably Achievable) approach is implemented to minimize worker radiation exposure through: minimizing time near NORM sources, maximizing distance from contamination, using shielding where practical, and using appropriate PPE (respiratory protection, gloves, coveralls) when handling NORM materials. |
| NORM awareness training | All workers who may encounter NORM in their duties receive initial NORM awareness training covering: what NORM is, where it is found in oil and gas operations, health hazards, how to recognize NORM-contaminated equipment (tags/labels), and reporting procedures. Training is documented and refreshed at intervals required by the NORM management plan. |
| Specialized NORM handler training | Workers who handle, transport, characterize, or dispose of NORM waste receive additional specialized training covering: radiation survey techniques, proper PPE selection and use, waste packaging and labeling, transportation requirements, emergency procedures for NORM spills, and applicable state regulations. Training records include date, content, trainer qualifications, and attendee verification. |
| Emergency procedures for NORM releases | Procedures exist for responding to unplanned NORM releases (spills, equipment failures, transportation incidents). Procedures address: area isolation, notification of RSO and state agency, exposure assessment, cleanup methods, waste management, and incident documentation. Emergency contacts are posted. |
Recordkeeping and Reporting
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Survey and characterization records | All radiation survey records, waste characterization analyses, and equipment survey logs are retained for the period required by state regulations (typically 3-5 years or life of facility). Records are organized by facility, date, and equipment and are readily retrievable for regulatory inspection. |
| Disposal and transfer records | Records of all NORM waste disposal events include: date, waste description, volume/mass, radionuclide concentrations, disposal facility name and permit number, manifest or tracking numbers, and transporter information. Transfer of NORM-contaminated equipment is documented with receiving party and NORM status. |
| Worker exposure records | Individual radiation exposure records are maintained for the duration of employment plus 30 years (per OSHA and most state requirements). Records include worker identity, dosimetry results, bioassay results where applicable, and cumulative dose. Records are accessible to the worker upon request. |
| Regulatory reporting compliance | All state-required NORM reports are submitted on time, including: initial notifications to the state radiation control agency, annual NORM reports where required, disposal reports, incident reports for NORM spills or overexposures, and license or registration renewals. |
Corrective Actions
Common Issues and Responses
- No baseline NORM survey conducted: Contract with a qualified NORM survey company to conduct baseline radiation surveys of all production equipment, piping, vessels, and facilities. Prioritize equipment with known NORM accumulation risk (heater-treaters, separators, produced water systems, wellheads).
- NORM-contaminated equipment not labeled: Conduct a facility-wide survey to identify all NORM-contaminated equipment. Tag or mark all items exceeding state action levels. Establish a tracking system for labeled equipment. Train field personnel on labeling requirements.
- Improper NORM waste disposal: Immediately cease any unauthorized disposal practices. Characterize remaining waste and arrange disposal through approved pathways. Report prior unauthorized disposal to the state agency if required. Implement waste handling procedures and training.
- No worker NORM training program: Develop and implement a NORM awareness training program for all field personnel. Provide specialized training for NORM handlers. Document all training. Consider using third-party NORM training providers with oil and gas industry expertise.
- Missing or expired instrument calibrations: Remove instruments from service until recalibrated. Send instruments to an accredited calibration laboratory. Implement a calibration tracking system with advance reminders for upcoming due dates.
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Compliance Calendar
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Corrective Actions
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