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NORM and TENORM waste disposal

Naturally occurring radioactive material from oil and gas operations, and how it concentrates.

NORM is naturally occurring radioactive material, and TENORM is NORM concentrated by industrial processes. In oil and gas it accumulates as radium bearing scale and sludge inside production equipment. It is regulated by state programmes rather than federally.

Source: State NORM programmes; not federally regulated under RCRA

Where NORM concentrates

  • Scale inside production tubing, valves and separators
  • Tank bottoms and sludge from produced water handling
  • Filter media and pigging waste from pipelines
  • Contaminated equipment during workover and decommissioning
  • Produced water treatment residues
  • Gas processing equipment where radon daughters plate out

Radium-226 and radium-228 co-precipitate with barium and strontium sulfate scale. Equipment that has handled produced water for years can carry significant concentration in a thin internal layer.

State by state, not federal

NORM is not regulated under RCRA. Individual states run their own programmes with their own exemption levels, licensing and disposal requirements, and those levels differ materially between neighbouring states.

Louisiana and Texas both have established NORM programmes reflecting the scale of their oil and gas industries. A generator operating across state lines can find the same scale regulated differently on either side of a border, which is a planning question rather than a surprise if it is checked early.

How we handle it

  • Survey and characterization to establish activity levels
  • Determination of applicable state programme and exemption thresholds
  • Equipment decontamination where reuse is the objective
  • Packaging and transport under state and DOT requirements
  • Routing to licensed NORM disposal, typically injection or specialist landfill
  • Documentation meeting the relevant state programme

Common questions

Is NORM regulated under RCRA?

No. NORM and TENORM fall outside RCRA and are regulated by state programmes. That is why requirements differ between states and why the applicable programme has to be established before planning a stream.

Can contaminated equipment be cleaned and reused?

Often yes. Decontamination removes scale and can return equipment to service, which is usually far cheaper than disposal and replacement. The scale removed becomes the waste stream.

How is NORM measured?

By survey instrument for screening and by laboratory analysis for radium-226 and radium-228 concentration. Exemption levels are set in picocuries per gram and differ by state.

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This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.