Oil and gas field wastes and sites contaminated with naturally occurring radioactive materials (NORM) have quickly become a focus of substantial attention by regulators both at the state and federal level. Although currently regulated in a number of states, the Environmental Protection Agency (EPA) has indicated a desire to develop federal regulations to address management and disposal of NORM-contaminated wastes.

This paper provides a brief overview of current state NORM regulations, currently available technologies for managing and disposing NORM wastes, and the cost of employing these techniques. Based on these characterizations and alternative assumptions about the volume of NORM wastes, four alternative scenarios have been developed to bracket potential future NORM requirements. These scenarios have been used as the basis for an analysis of the potential economic and supply impacts of NORM requirements on the U.S. oil and gas industry.

The results illustrate that a reasonable approach to regulation that focuses only on those NORM wastes that pose a risk and allows producers to use safe, low cost disposal methods (downhole or other) would have minimal economic impacts on the oil and gas industry. A very stringent regulatory approach that covered large volumes of wastes, required the use of higher cost disposal techniques, and required extensive site clean-up activities could have a substantial economic impact, resulting in a loss of up to 20 percent of U.S. oil production and 8 percent of U.S. gas production by 2000. The costs of compliance with these alternative approaches could range from $71 million to over $14 billion annually. Between these two cases lies the opportunity for regulators to develop requirements for management and disposal of NORM wastes that will address any environmental and human health risks posed at industry sites without imposing unnecessarily costly regulations on the U.S. oil and gas E&P industry.

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