U.S. STATES WITH NORM/TENORM REGS
The most prevalent eight oil and gas states that possess NORM/TENORM regulations are: Arkansas, Louisiana, Mississippi, New Mexico, North Dakota, Ohio, Texas, and West Virginia.
After a recent review of states that possess NORM/TENORM-specific regulations, the following states can be added to the list: Florida, Georgia, Maine, Michigan, Minnesota, New Jersey, Oregon, and South Carolina.
Even though some states do not possess NORM/TENORM-specific regulations, they may have regulations concerning radium or uranium concentration restrictions in produced water released into surface waters, or plug and abandonment for wells. These states include: Kentucky, Pennsylvania, and Wyoming.
OPERATOR REGISTRATIONS IN WEST VIRGINIA
CUSTOMER INFORMATION IN PIA REQUESTS
In various states, NORM/TENORM specifically licensed companies are required to provide certain customer information in reporting document lists, such as initial and ending temporary job site notifications. Customer names, addresses and phone numbers exist within the realm of “Confidential information – Trade Secrets, Competitors, and Financial Information”.
Notifications containing client or customer information are confidential, and will be withheld from open record requests and public information act requests when properly marked. Within these laws, states may possess language similar to the below statements on confidential information.
In order to protect the identity of your clients/customers in Texas, all initial job notifications should include the following verbage in BOTH the header and footer, with no other information above the header or below the footer:
WITHHOLD FROM PUBLIC DISCLOSURE PURSUANT TO TEXAS GOVERNMENT CODE 552.110 – NOT AN OPEN RECORD.
Remember, all financial information is submitted under separate cover from technical data.
NORM CONFERENCE MARCH 14-16, 2016
The NORM & Natural Radiation Management North America Conference will be March 14-16, 2016 in Houston, TX. The conference is offering maximum of two (2) free VIP passes for NORM Waste Producers per company. Many regulatory officials will be attending and presenting on a variety of topics. Geri Blanchard of NORM SOLUTIONS LLC is working on a speaking agreement.
TENORM RULES EFFECTIVE NORTH DAKOTA!
The North Dakota Department of Health previous draft rules are now effective as of January 1, 2016. The final draft rule was in acted as a final regulation. The waste disposal limit for landfills is raised from 5 pCi/g of Radium226 and Radium228 to 50 pCi/g, however landfills must apply to the Department of Health to have the authorization to accept higher concentrations.
Oil and Gas E&P operators and producers are required to register as general licensees, and list their TENORM-contaminated sites with the NDDOH. Transfers must be reported to the the NDDOH. If a transporter hauls TENORM over 5 pCi/g of Radium226 and Radium228, they must possess a specific license from the NDDOH for the transportation of the material. They must have an RSO listed on their license application. The TENORM regulations provide a sixty (60) day window for compliance.
ENVIRONMENTAL CONFERENCE 2015
The Oil and Gas Environmental Conference will be an ideal opportunity to learn about new regulatory changes affecting the industry. This will be a forum to network with oil and gas industry decision makers, technical experts, regulators and executives as well as a place to exchange new ideas and concepts related to the Oil and Gas Industry environmental performance and measurement. All with the overriding goal of achieving better environmental performance and regulatory compliance in the Oil and Gas Industry.
RMLLWB NORM MEETING 10-15-15
The Rocky Mountain Low-Level Waste Board will hold a Regular Meeting October 15, 2015, at the Eldorado Hotel & Spa, 309 West San Francisco, Santa Fe, NM. The Regular Meeting will begin at 8:30 a.m. Interested parties and the public are welcome to attend, and there will be an opportunity for public comment at the meeting. If you would rather receive an e-mail notice of Board meetings, please contact Jessica Ernst at email@example.com or (303) 825-1912. The most recent agenda listed on the RMLLWB website is stated below.
- Executive Session (Re: Discuss Legal Advice Regarding Proposed Rule Concerning Executive Director Discretion on Export and Import Applications)
- Approval of Minutes of June 24, 2015 Regular and Annual Meetings
- Notice of Actions taken at September 2, 2015 Telephonic Meeting
- Oil and Gas Waste Regulation and Oil and Gas NORM Regulation in the Member States Facilities in the Member States that Commercially Dispose of Oil and Gas Waste
- Public Comment on Oil and Gas NORM Waste
- Discussion on Future Board Activities Concerning Oil and Gas NORM Waste
- Rule(s) Amendment Regarding Executive Director’s Discretion on Export and Import Applications
- Executive Director’s Report
- Investment Options
The order of matters on this agenda is subject to change without notice.
RAMPING UP DECON FOR END OF 2015
It has been common that in the last several years for operators, producers, and facilities to initiate NORM/TENORM decontamination projects prior to the end of the year. Since the end of the year for many operators, producers, and facilities signifies the termination of available budget funds, then we typically see an increase in decontamination activities. There are two spikes within the calendar year in which decontamination licenses are applied for: the beginning of the spring and the end of the summer. Although 2015 has not followed the exact patterns of the subsequent previous years, trending has existed none the less.
RSO TRAINING IS SPECIALIZED!
Radiation Safety Officer (RSO) Training is the top level of radiation training available. Courses can be in various time increments, and are specialized to whatever activity and industry the attendee’s use will entail. There are medical RSO courses, nuclear RSO courses, industrial radiography RSO courses, well-logging RSO courses, and NORM/TENORM RSO courses. All of these RSO courses must be approved by the Nuclear Regulatory Commission (NRC), with the exception of NORM/TENORM RSO training. Since NORM/TENORM is regulated at the state level, the states have the discretion to instate an approval process for training programs.
Every RSO course NORM SOLUTIONS LLC provides specializes in NORM/TENORM, and does not cover sealed sources, gauges, well-logging, or industrial radiography. NORM/TENORM RSO courses are not registered or approved by the Nuclear Regulatory Commission (NRC), and may be only in states that possess a training program approval process for NORM/TENORM.
When applying for specific licenses, the RSO course must specialize in the area that the applicant is applying for or complying with. There is no one (1) RSO course that will include all areas and act as an overall class for every purpose. Industrial RSO courses do not sufficiently cover NORM/TENORM, as the course would have to be 80-hours in length. It is possible that an individual may need to attend both an industrial RSO course and a NORM/TENORM RSO course depending on their job responsibilities. Industrial RSO courses do not satisfy state agency NORM/TENORM RSO training requirements to issue NORM/TENORM decontamination licenses. NORM/TENORM RSO courses do not satisfy industrial radiography RSO training requirements.
NORTH DAKOTA DRAFT RULES UPDATE
The North Dakota Department of Health has recently stated that due to the overwhelming response from the public comment period, some changes are being made to the current draft rules as suggested. The Department anticipates that the rules will become effective at the beginning of 2016. Refer to the North Dakota DOH for more information in the next several months.