Responding to the public's concern over radioactive contamination, the perceived need to protect the health of employees, the public, and the environment, and the need to control the spread of contaminated materials into commerce and unrestricted areas, have led regulatory agencies, both state and federal, to develop regulations for the control of NORM.
As a result, regulations for the control of NORM are being developed at an increasing pace by the petroleum producing states. At the present time, Louisiana, Mississippi, and Arkansas are the only states with NORM regulations in effect, but several others, including Texas, Alabama, Kentucky, New Mexico, and Oklahoma could have their regulations in effect during 1993. It is expected that the majority of the petroleum producing states will have regulations within two to three years.
The federal government is also considering regulations for the control of NORM, and it is probable that the Environmental Protection Agency will develop federal regulations for NORM control. Some of the Canadian provinces, e.g., British Columbia, Alberta, and Saskatchewan, will also have NORM regulations shortly.
There is still some controversy over acceptable exemption levels for radium. More data, particularly accurate measurements of radon emanation rates and better risk assessments for NORM exposures, are needed. The impact of the regulations on the petroleum industry will be very costly and will require some changes in operating procedures.
The need for a uniform regulatory posture regarding process residues containing NORM has been recognized by federal and state radiation control agencies for several years. Radium and its progeny are the primary radionuclides of concern. These wastes cannot be regulated by the Nuclear Regulatory Commission under present law. Currently both federal and state agencies are actively considering the need to extend general regulations for management of radioactive wastes that contain NORM.
Impetus for this activity has come from a growing awareness that such wastes can attain levels of radioactivity that exceed limits set for wastes from other industrial activity. Unforunately, data to quantify the extent of possible hazards posed by NORM on the petroleum industry waste are not generally available. Regulatory limits applied to management of other low level radioactive waste should be adapted to control petroleum industry NORM only after risk assessment of current practices has provided a basis for taking action.
The major reasons that regulatory agencies feel that some regulation of NORM is necessary are:
Concentrated NORM can increase risk from direct exposure to radiation, increased radon concentrations, and inhalation and ingestion of radon and other NORM radionuclides.