Gas NORM Regulations

Anyone who mines, extracts, receives, possesses, owns, uses, processes, transports, stores, transfers for disposal, or recycles NORM is automatically a general licensee.

Persons who are intentionally decontaminating facilities, land, or equipment owned, possessed, or controlled by others who treat or process NORM waste generated by others are required to have a specific license from the Texas Department of State Health Services for the activity. Persons who move their decontamination operations from site to site are not required to be licensed for each individual site.

A specific license is not required to do a NORM survey.

No, neither DSHS's §289.259 nor RRC's Subchapter F specifically require NORM surveys; however, operators are required to identify NORM-contaminated equipment with tags or markings. A NORM survey is necessary to make that determination.

No, because removing tank bottoms from vessels is considered routine maintenance.

No time limits on storage are included in §289.259.

Neither DSHS nor RRC regulations require that the land be decontaminated with a certain time; therefore, the operator may wait to decontaminate the land. Eventually, the land must be decontaminated before lease activities cease (plugged and abandoned). However, there may be other considerations that warrant a prompt decontamination of the site.

No, the requirements of both rules must be met; however, land farming or land spreading may be a viable method to meet those requirements.

Subchapter F does not require that an operator seek the approval of the landowner before disposing of NORM waste that was generated on the same lease. However, the operator should be sure that the lease agreement does not preclude on-lease disposal of NORM.

• If it is still usable, it can be used again for the same purpose (i.e. oil and gas production);

• It can be decontaminated, then sold, recycled, dispose of, etc, like a waste not contaminated by NORM;

• It can be recycled by delivering it to a scrap dealer provided that dealer will accept the material;

• It can be placed in a well that is being plugged and abandoned;

• It can be disposed of by commercial oil and gas NORM disposal company that is permitted to dispose of such waste.

No, because the transport of NORM is under DSHS jurisdiction.

A minor permit is required only if a minor permit is necessary for that type of waste regardless if it contains NORM. For example, a minor permit is necessary to move tank bottoms, but not move tubing.

As a matter of administrative policy, the signs should use one inch tall letters consistent with the sign requirements of Statewide Rule 3 which reads: "The signs and identification required by this section shall be in the English language, clearly legible, and ... shall be in letters and numbers at least one inch in height."

Very limited information is available; however, the RRC compiled a list of producing fields where leases or facilities where RRC surveys identified NORM-contaminated equipment from a survey of more than 600 leases and facilities.