Feasibility of re-melting NORM-contaminated scrap metal

Naturally occurring radioactive materials (NORM) sometimes accumulate inside pieces of equipment associated with oil and gas production and processing activities. Typically, the NORM accumulates when radium that is present in solution in produced water precipitates out in scale and sludge deposits. Scrap equipment containing residual quantities of these NORM-bearing scales and sludges can present a waste management problem if the radium concentrations exceed regulatory limits or activate the alarms on radiation screening devices installed at most scrap metal recycling facilities. Although NORM-contaminated scrap metal currently is not disposed of by re-melting, this form of recycling could present a viable disposition option for this waste stream. Studies indicate that re-melting NORM-contaminated scrap metal is a viable recycling option from a risk-based perspective. However, a myriad of economic, regulatory, and policy issues have caused the recyclers to turn away virtually all radioactive scrap metal. Until these issues can be resolved, re-melting of the petroleum industry's NORM-impacted scrap metal is unlikely to be a widespread practice. This paper summarizes the issues associated with re-melting radioactive scrap so that the petroleum industry and its regulators will understand the obstacles. This paper was prepared as part of a report being prepared by the Interstate Oil and Gas Compact Commission's NORM Subcommittee.