Delivering New Oilfield Waste Strategies

Regulations governing solid waste disposal, including radioactive materials, from drilling operations in the Bakken are getting an overhaul to improve efficiency and lower costs without endangering public safety or the environment.
By Patrick C. Miller | June 17, 2015

Regulations governing solid waste disposal—including radioactive materials—from drilling operations in the Bakken are getting an overhaul to improve efficiency and lower costs without endangering public safety or the environment.

New NORM reuse efforts
As Scott Radig, director of the North Dakota Department of Health’s waste management division, puts it: “The philosophy and general policy of the department is that North Dakota should take care of its own issues that we generate here to the extent that it’s still safe for the public.”

Waste treated on the well site is regulated by the North Dakota Industrial Commission Department of Mineral Resources Oil and Gas Division. Waste transported off-site for treatment or burial in landfills is regulated by the state health department.

Before the Bakken production boom in 2008, oil and gas had just one or two treating plants to regulate, says Mark Bohrer, Oil and Gas Division underground injection control manager. Now there are 20, which resulted in the regulations being updated in April 2014.

“We revised our rules and regulations to cover a myriad of facilities that might be out treating or processing oilfield wastes to bring those under our jurisdiction under our treating plant rule,” he says. “Every treating plant is different. It’s not like permitting an oil well where they’re pretty much all the same.”

In a state that produces up to 2 million tons of solid drilling wastes annually, one of the few options until recently was to bury it in a special waste landfill. That changed last May when the North Dakota Legislature passed House Bill 1390. The bill authorized the state’s Department of Health to select one or more pilot project projects to recycle drilling wastes for beneficial uses.

On June 8, Gov. Jack Dalrymple announced that the Nuverra Environmental Solutions plant at Watford City, North Dakota, had been selected as the first pilot project participant under the new law. Using Nuverra’s Terrafficient solids management process, the plant will recycle drill cuttings for use in such applications as road bases, gravel additives, construction fill and flowable fill.

“The problem that we looked at with the landfills was that it’s legal and it works very well, but you’re really not changing the product itself,” according to Mark Johnsrud, board chairman and CEO of the Arizona-based company.

Running the cuttings through the Terrafficient process not only turns them into non-hazardous useful products, but also recovers water and hydrocarbons for reuse while reducing carbon emissions, he explains.

“Changing the profile of the byproduct was really the direction that we thought we needed to go,” Johnsrud says. “That’s how we could end up reducing or eliminating the risk for the operators. We can make sure from an environmental standpoint that we can do what’s very earth friendly, and we just think that it’s a good overall management tool for companies to use today.”

The bill requires that a company selected for the pilot project “be supported by scientific findings from a third-party source focused on the anticipated environmental performance of the end products.” On the science side, Nuverra is working with the Energy & Environmental Research Center at the University of North Dakota.

“It takes good solid economic and science validation in order for this program to be successful,” Johnsrud says. Nuverra chose the EERC because the company had a good working relationship with the center, it belonged to the EERC’s Bakken Optimization Program and because of the EERC’s work with the North Dakota Petroleum Council.

Alison Ritter, public information officer for the state Oil and Gas Division, notes that one of the important aspects of HB1390 is that it removes the liability from a producer that gives its drill cuttings to a company for recycling. Previously, companies could treat only their own wastes products.

“The material actually has to be processed first and turned into the beneficial use before the liability is released,” she explains. “One company can now take waste from another company and turn it into something good; there’s no liability for the other operator.”

Although recent low oil prices have reduced the amount of drilling wastes being produced, Bohrer believes that the recycling option is a good long-term solution.

“With the volume of waste that’s going to be generated throughout the life of the play, it just makes sense to reuse some of it,” he says.

Johnsrud says Nuverra’s Watford City plant has been approved by the Health Department and is already processing drill cuttings from customers.

“We’re just trying to fine-tune our operations,” he says. “We anticipate that either by the fourth quarter of this year or the first quarter of 2016 that we’ll be commercially operational. We’re still doing our testing and ramping up the process as we go.”

Radig says that the health department currently regulates 12 oilfield waste disposal facilities in North Dakota

“With the slowdown in drilling, the volumes going to those landfills has definitely decreased,” he says. “Over the long-term life of drilling in the Bakken, I would anticipate that there will be a number of additional special-waste landfills permitted. If this beneficial use and recycling takes off, that may change that picture.”

TENORM’s trek
Another waste product from drilling is TENORM—technologically enhanced naturally occurring radioactive material. It’s typically found in areas where radioactive waste tends to concentrate, such as in filter socks, heater treaters, sludge accumulated in saltwater storage tanks and in the scale of old, corroded pipelines.

“Currently and previously, the limit was 5 picocuries per gram of radium,” Radig says. “Anything above 5 was considered regulated material. No material regulated by the radiation control rules could be taken into landfills in the state.”

Currently, TENORM can only be disposed of by being trucked to far away landfills in other states such as Idaho and Colorado—a very expensive process.

“The cost of transportation is higher than the disposal fee,” says Kathleen Spilman, managing director of Keitu Engineers and Consultants Inc. in Mandan, North Dakota. “And this is done at a facility that’s permitted to take contaminated materials from a nuclear power plant. It’s like going gopher hunting with an elephant gun—it’s overkill.”

Founded in 2001, one of the Keitu’s specialties is helping producers properly handle and dispose of TENORM within state regulations. The firm has four trained industrial hygienists, including Spilman.

“We’re members of the American Industrial Hygiene Association,” she says. “It’s not something where you go to a class and declare yourself a radiation safety officer. It’s a practice area for us.”

In addition to making recommendations for TENORM metering equipment, training employees how to use it and developing protocols, Keitu also works for companies seeking to obtain permits for special-use landfills.

“We can complete the permit application itself and compile the engineering data, participate in the public hearings, work with the health department, oversee construction and audit the operation at the facility from time to time,” Spilman says. “All those types of aspects are being folded into the regulations associated with operating a special waste landfill in North Dakota.”

The TENORM disposal issue could soon change if new rules proposed by the North Dakota Department of Health are adopted. One recommendation is to raise the level of radiation accepted in the landfills from 5 picocuries to 50. The higher level was based on a study conducted by the Argonne National Laboratory for the health department using risk models and risk evaluation.

“They determined that a level of 50 picocuries per gram of radium would be a very conservative and a safe limit that the landfills here could accept,” according to Radig. “Once this rule goes into effect, special waste landfills for large volume industrial landfills in North Dakota could apply to the health department to change the permit to accept that type of waste (TENORM).”

The rules call for a cradle-to-grave, record-keeping system that accounts for where the TENORM is generated at each saltwater disposal facility or oil well, who picks it up and where it’s delivered for final disposal, Radig says.

TENORM emerged as a problem in 2014 when filter socks were found illegally dumped in abandoned buildings and along roadsides. Spilman says the problem was partly caused by some producers not doing due diligence on businesses disposing of TENORM and dishonest businesses taking advantage of the situation. She also believes the current standard of 5 picocuries for waste to be classified as TENORM is unreasonable.

“To put it in perspective, under the 5 picocuries limit, technically you couldn’t dispose of Brazil nuts; you couldn’t throw them in a special-use landfill,” she says. “Even some coffee we’ve tested exceeded that level.”

Radig says 5 picocuries wasn’t originally intended to be the regulatory standard, and that’s why the new standard was set at 50 picocuries based on the Argonne study.

Without making excuses for industry, Spilman says the dumping of filter socks wasn’t a common practice, nor was it characteristic of how most producers operated.

“I will tell you that some of the oil companies we’ve worked with have been isolating those socks from the get-go,” she says. “They’ve been putting them in containers and disposing of them properly in facilities that are permitted for much higher levels of radioactivity. Their socks have been properly isolated from being a threat to human health and the environment.”

Last year, the health department worked with Oil and Gas Division to implement an order requiring a special container designated only for filter socks or other TENORM material be on site at every saltwater disposal well and every well up through the point of drilling and completion.

“Any filter socks or TENORM material that was in those containers needed to be transported by a licensed company to a licensed disposal facility,” Radig said. “After that went into effect June 1 of last year—one year ago—the number of illegal dumpings in road ditches or abandoned buildings essentially went away. We’ve had only one since that time. I’m sure it was probably in that location before that requirement went into effect.”

“We’ve had comments from industry saying they’d like the North Dakota limit to be the same as Idaho or California or Colorado, which would be 1,500 picocuries per gram,” he says. “Our study—with the type of procedures we currently have—indicates that 50 is an appropriate limit at this time.”

Spilman says that one-size-fits-all solutions don’t work. Each problem requires a tailored solution.

“As an engineer, I still go back to what’s necessary,” she says. “The difference between engineering and science is that we’re always looking at the cost factor—we’re looking at the best alternative. If it’s not an adequate alternative, if we’re not providing adequate protection, it’s not even an alternative.”

Still, Spilman says the key is to provide industry with options at a realistic cost when it comes to TENORM disposal. “From the regulated community’s standpoint, the vast majority of the oil companies—if they have a reasonable cost and a reasonable alternative—are happy to dispose of it properly because we all live here,” she explains. “We don’t want to contaminate where we live and where our kids are going to grow up.”

Author: Patrick C. Miller
Staff Writer, The Bakken magazine