tenorm north dakota’s journey to rulemaking. beginnings 2013oil industry is on the move – 200+...
TRANSCRIPT
TENORM
North Dakota’s Journey to Rulemaking
BEGINNINGS
• 2013 Oil industry is on the move– 200+ rigs operating capable of 20,000 feet or
more– 167 Billion barrels of oil in place– 7.38 billion barrels are recoverable wusing current
technology
Current Production
• 12,684 producing wells• 1,211,178 barrels per day (8-14-2015)• 1,650,075 MCF/day (natural gas) 8-14-2015– Currently capturing about 75% of natural gas– 25% flare
• End Result?– 50,000 to 70,000 wells drilled
2-20 yard Rolloff containers
Problem Solved?
• Effective June 1, 2014, covered, leak-proof containers designated for filter sock disposal are required to be on-site at saltwater disposal wells at all times and on-site during the drilling, completion and flow-back phases of all new spud (drilled) oil and gas wells.
Licensed Haulers
• On March 13, 2014 the Department of Mineral Resources notified all North Dakota well operators that they must use waste haulers licensed by the North Dakota Department of Health.
Current Disposal Options
• Less than 5 pCi/g– Disposal in local landfill
• 5 pCi/g or more– Oaks (Baranko) in Montana– Clean Harbors (Colorado)– US Ecology (Idaho)
How much Waste is generated
• 63 cubic yards per day• This is equal to 3 twenty yard roll off dumpsters
• In terms of weight:– Approximately 131 tons per day• This could include any of the following:
– Frac sand– Tanks bottoms– Scale– Metal parts including pipe, valves, and other steel– Filter socks
Can we Raise the Disposal Limit?
• Argonne National Lab conducted study– $182,000.00– Sampling data was not used– Worked backwards from the public dose limit of
100 mrem– Calculations based on Special Waste Landfill
design– Acceptable disposal concentration 51.6 pCi/g– North Dakota decided to use 50.0 pCi/g
Rule Making Process
• Draft rule promulgated late 2013 based on CRCPD SSR part n– New chapter to the North Dakota Radiological
Health rules (33-10-23)– Some additions include:• Waste hauler licensing• Applicant background and criminal history check• Specific record keeping requirements• RSO training requirements for certain license types
Public Hearings
• North Dakota rules require 30 day notice of public hearing
• One public hearing is required• 30 day comment period required
• North Dakota held 3 public hearings and extended the comment period to 80 days
Public Comments
• https://www.ndhealth.gov/EHS/TENORM/Rules/NDDoH%20Response%20to%20TENORM%20Comments.pdf
• 107 pages of comments with department responses
Proposed Rules
• https://www.ndhealth.gov/EHS/TENORM/Rules/FINAL%20Radiation%20Control%20TENORM%20Rules%20-%20NDAC%2033-10-23.pdf
Next Steps
• 8-12-2015 Approved by North Dakota Health Council
• Waiting on Attorney General opinion– Then on to the Legislative Rules Committee– Published by the Legislative Council• Once published, rules are final
– Probably early 2016
