Practical Implications of Gradual NORM Accumulations in Storage Tank Sludges to Waste Removal Actions

Abstract

Abstract A Waste Removal Action has been conducted at a former oil reclamation plant located in Grapeland, Texas. This site is a listed Texas State Superfund Site, identified as the McBay State Superfund Site (McBay). The waste removal action was conducted under the regulatory authority of both the Texas Natural Resource Conservation Commission (TNRCC) and the Railroad Commission of Texas (RRC). This was the first and, to date, only site removal action both of these regulatory agencies have overseen concurrently. Throughout several decades extending back to the 1930's, the McBay site had been used for various operations, including gas recycling, oil field parts storage, and oil reclamation. The bulk of the environmental issues which landed the site on the State Superfund list stemmed from operations associated with the oil reclamation operations. Historical documents reveal that the plant received regulated wastes including petroleum refining wastes, waste motor vehicle lubricating oils, barge bottoms, tank bottoms, and slop oil during its oil reclamation operations. The TNRCC and RRC shared waste characterization and removal oversight, with each agency defining its particular requirements in separate Agreed Orders. Subsequent to the development of the Agreed Orders, a site evaluation suggested the potential of wastes and waste containers impacted by Naturally Occurring Radioactive Materials (NORM). The differing focus of the agencies has resulted in a thorough and unique approach to site characterization, waste disposal, and waste recycling, especially as concerns NORM wastes. The application of regulatory guidelines has also resulted in a unique mixture of hazardous waste exemptions as defined under TNRCC, RRC, and Texas Department of Health (TDH) NORM regulations. NORM concentrations detected at the McBay site were compared to a database of exploration and production (E&P) waste characteristics developed primarily through ThermoRetec’s extensive work with both the American Petroleum Institute (API), and The Gas Research Institute (GRI). Data was also compared to TNRCC and RRC regulatory standards, including hazardous waste thresholds, Class 1 waste thresholds, and used oil thresholds.