In a letter dated November 7, 2017, the Colorado Department of Public Health and Environment (CDPHE) wrote a letter to solid waste landfill owners, oil and gas operators, and other stakeholders regarding guidance for the management and disposal of technically enhanced naturally occurring radioactive material (TENORM) waste by the oil and gas exploration and production (E&P) industry. In this letter, CDPHE states it is pursuing changes to the Radiation Control Act, allowing the development of TENORM regulations. While these changes are developed, the Division is implementing its "Interim Policy and Guidance Pending Rulemaking for the Control and Disposition of Technically Enhanced Naturally Occurring Radioactive Materials in Colorado" with modifications.
E&P waste streams with the potential for high TENORM concentrations are prohibited from disposal in all landfills not specifically approved to receive them. These waste streams include:
- Tank bottoms (solids and liquids)
- Filter socks
- Filter press cake or sludge
- Discarded pipe and flow line sections
- Residual materials dislodged during cleaning and maintenance activities on pipelines, flow lines, connector pipes, tanks, and vessels
The guidelines state TENORM Administrative Release Levels as follows:
- Combined Radium-226 and Radium-228 (Ra-226+Ra-228) < 3 pica Curies per gram (pCi/g) above background
- Natural Uranium < 30 pCi/g above background
- Natural Thorium < 3 pCi/g above background
Talon/LPE has been working with accredited laboratories for collecting and analyzing potential TENORM waste streams for characterization for disposal. Each site waste stream is collected and submitted to the laboratory for analytical analysis of gamma and alpha emitting nuclides. The laboratory analytical results are then compared to the CDPHE TENORM guidelines and Administrative Release Levels to ensure the waste is compatible with landfill disposal requirements.
For more information in regards to the TENORM regulations, please contact us using the button below. Talon/LPE's experienced and knowledgable staff located in our Fort Collins, Colorado office will be more than willing to answer any questions you may have.
