Incidents regarding technologically-enhanced, naturally-occurring radioactive materials (TENORM) have generated a fair amount of concern among western North Dakota’s citizens and local officials.
Media have reported on several businesses haphazardly discarding TENORM waste, blatantly violating North Dakota solid waste disposal regulations. These incidents have been sensationalized by some reports and letters, creating a misunderstanding of basic facts about dangers and risk to the public.
TENORM presents low risk to the average oil worker and lower risk to a non-oil worker. However, those working directly around TENORM are at increased risk of breathing or ingesting particulates, underscoring the need for worker training, use of personal protective equipment and a proactive approach to responsible management of this waste.
Oil and gas TENORM follows two major pathways — produced water and gas streams. North Dakota currently supports 500-plus salt water disposals, a quarter being commercial. Fluids are filtered prior to disposal, generating millions of filters socks annually. Haphazard disposal of these filters raises the risk of inadvertent inhalation or ingestion by the public and is a completely preventable risk.
Prior to proposing major policy changes, state officials have commissioned Argonne National Laboratory to conduct a risk assessment relative to landfill disposal in North Dakota. In the meantime, our state and local leaders need to cooperatively develop a powerful, safety-based communication strategy, effective interim policy for safer management of these wastes and enforcement actions with teeth. These activities can and should happen while awaiting results from Argonne.
One thing is certain; reactive regulation would be ineffective — oftentimes overreaching and overly restrictive. While municipal landfill operators have reacted swiftly, and rightly, by steeply increasing fines for illegal dumping at their facilities, state regulators and local officials should work with industry and TENORM specialists to develop policies to protect workers and the public.
In a perfect world, good policy for TENORM management would be in place today. In the real world, it seems policy making takes time. That notwithstanding, the time has come to establish a dependable framework for managing TENORM responsibly, and we owe it to our communities to explain how we’re going to arrive at that destination.
In the meantime, we as an industry ask the media to provide balance to their reporting. Yes, TENORM disposal has issues to address, but is all of western North Dakota going to be designated as a superfund site? No. Are we all going to be wearing lead aprons in the near future? No. The media has a responsibility to provide content to inform and educate, rather than incite a populace with stories that misrepresent risk to the public.
(Erickson is the owner of Plains Energy Technical Resources, LLC.)