(NOTE: Images, documents and a video have have been added to the original blog)
The Appalachian LLRW Compact includes Pennsylvania, Delaware, Maryland and West Virginia.
Rich Janati, DEP Bureau of Radiation Protection, explained, “TENORM is mainly from fracking operations, a lot of it in Pennsylvania. It contains radium with a 1,600 year half-life.”
In 2021, DEP reported 236,150 cubic feet of TENORM (Technically Enhanced Naturally Occurring Radioactive Material) was sent to LLRW facilities for disposal, while all other industries combined in the four state compact sent 46,546 cubic feet of traditionally defined low-level radioactive waste.
From 2016 to 2021, a total of 811,070 cubic feet of TENORM waste was sent to low-level radioactive facilities for disposal, while all the other industries combined in the four states sent 1,272,003 cubic feet of LLRW.
In terms of radioactivity, the TENORM waste represented just 3.74 Ci (curies), while the low-level radioactive waste shipped for disposal represented 1,682 Ci.
More radioactivity is expected from the other sources because they include nuclear power plants.
Waste generators often send their waste to more environmentally secure facilities when they are concerned about the potential cleanup liability in less environmentally secure facilities.
Janati said the Appalachian Compact keeps track of TENORM waste for the purpose of reporting and recording of waste, even though it isn’t by definition low-level radioactive waste
“[There’s] a lot of activity going on in the area of fracking operations, treatment of wastewater from fracking operations. So, the sludge that’s generated as a result, is sent to Energy Solutions or WCS in Texas,” said Janati.
“We definitely should be concerned about TENORM, but relative to low-level waste, the radioactivity level is by far smaller. Volume is high. Activity is low,” said Janati.
Click Here for a copy of Janati’s presentation to the Committee.
In June, DEP released updated guidance for handling radioactive waste from unconventional shale gas drilling operations going to solid waste processing and disposal facilities, but it does not cover conventional facilities. Read more here.
In addition to these requirements, DEP is also reviewing its policies for allowing the on-site disposal of radioactive and nonradioactive wastes where oil and gas well plugging will be done under the new federal Bipartisan Infrastructure Law plugging program. Read more here.
Currently, many conventional oil and gas drilling operations dispose of their waste, including drill cuttings which often meet the definition of TENORM waste, right on the drilling site. Read more here.
A study released in May by Penn State found radiation levels of conventional oil and gas drilling wastewater disposed of by uncontrolled spreading on roads contained levels of radioactivity exceeding industrial radiation discharge standards. Read more here.
The issue of fracking operations shipping TENORM waste out-of-state for disposal also came up in an October 2021 Senate hearing, where David Allard, then Director of DEP’s Bureau of Radiation Protection said, “But, the potential for environmental impact from spills or leaks of TENORM contaminated material is real. DEP will continue to closely monitor and evaluate landfill leachate for radium content above natural background levels to ensure public health and safety.” Read more here.
— Conventional Oil & Gas Drillers Reported Spreading 977,671 Gallons Of Untreated Drilling Wastewater On PA Roads In 2021 [PaEN]
— Conventional Oil & Gas Drillers Dispose Of Drill Cuttings By ‘Dusting’ – Blowing Them On The Ground, And In The Air Around Drill Sites [PaEN]