Radioactivity in the Oilfield: North Dakota Issues Material Handling Regulations Impacting Oil and Gas Operations

By J. Scott Childs and Guy Smith

On April 10, 2014, the North Dakota Industrial Commission (NDIC) announced new permit requirements for oil, gas and saltwater disposal wells. The new regulations, which go into effect on June 1, are targeted at the proper handling and disposal of used filter socks, which often collect naturally-occurring radioactive material (NORM). The new rules are as follows:

  1. Covered, leak-proof containers designated for filter sock disposal are required to be on-site at saltwater disposal wells at all times;
  2. Covered, leak-proof containers designated for filter sock disposal are required to be on-site during the drilling, completion and flow-back phases of all newly spud oil and gas wells; and
  3. All such disposal containers must be collected by waste haulers licensed in the State of North Dakota and properly disposed of at an authorized facility.
    Earlier this year, the NDIC notified all oil and gas well operators in North Dakota that they must use waste haulers licensed by the North Dakota Department of Health for transportation of all NORM.

These new regulations are generally viewed as a response to recent incidents of improper filter sock handling and disposal in North Dakota. In February, a service company working for a major oil and gas operator left two open-flatbed trailers loaded with used filter socks in Watford City, North Dakota. In March, authorities discovered an abandoned gas station in Noonan, North Dakota, filled with used filter socks.

Moving forward, in addition to the new NORM handling requirements, the North Dakota Department of Health recently commenced a NORM study and may also issue new regulations with respect to NORM handling and disposal as early as this summer.


To discuss compliance with the NORM regulations and the retention of licensed NORM disposal contractors in North Dakota, contact your usual Stinson Leonard Street contact.

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