The Gulf of Mexico (GOM) Offshore Continental Shelf (OCS) Regional Office of the Minerals Management Service (MMS) published a Letter to Lessees and Operators (LTL) dated November 20, 1990, concerning the reporting, disposal, and transportation of produced well solids containing naturally occurring radioactive materials (NORM). On December 11, 1991, the MMS published another LTL which provided clarification to the November 20, 1990, LTL. These interim guidelines are designed to provide operators with disposal options while also providing the MMS with data on the offshore oil and gas industry's handling of NORM-contaminated produced well solids. This paper will review the interim guidelines and current operational practices.
The Environmental Protection Agency (EPA) must publish Best Available Technology Economically Achievable (BAT) Guidelines and New Source Performance Standards (NSPS) by January 15, 1993, for the offshore subcategory of the oil and gas extraction point source category. In the development of these effluent limitation guidelines, EPA has conducted a field study to determine if the discharge of NORM-contaminated produced water had any bioaccumulation or biomagnification potential in shallow waters of the GOM. An American Petroleum Institute (API) study designed to assess risk factors of fish consumption near production platforms, will also be discussed.
Introduction
As an offshore operator your company has found NORM-contaminated solids in various platform's production vessels, tanks, and flowlines. In addition your company has pulled production tubing from numerous wells and has discovered that the hard barium sulfate (BaSO4) scale, which has reduced available internal diameter, is also NORM-contaminated. What regulations apply to your company's removal, handling, storage, and disposal of these materials?
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