Regulation of TENORM from Oil and Gas Operations Philip Egidi Meeting of the Low Level Waste Forum Denver, Colorado October 30, 2014

Regulatory Big Picture TENORM is not regulated under the Atomic Energy Act States have the regulatory authority to address TENORM issues More states taking action to address issues Requirements vary across states CRCPD White Paper in progress PA and ND studies under way EPA is maintaining awareness of these issues

Areas of Interest Aspects that we are watching and following: Comparison of TENORM production estimates Conventional vs. unconventional wells Different shale plays and geochemistry Different aspects of production (e.g., liquid vs. solid) Understand where TENORM is most likely to be released or present hazard to public health PA, ND, MD Studies

Waste Management States regulate oil and gas waste Office of Resource Conservation and Recovery (ORCR) issued two documents in April 2014 Compilation of publicly available guidance http://www.epa.gov/epawaste/nonhaz/industrial/special/oil/og_ep_vol_wste_mgt_%20prctcs_compilation_040114.pdf Regulatory review http://www.epa.gov/epawaste/nonhaz/industrial/special/oil/state_summaries_040114.pdf Not specific to TENORM

Superfund Guidance Office of Solid Waste and Emergency Response (OSWER) issued Q&As on “Radiation Risk Assessments at Superfund Sites” in July 2014 Supersedes 2009 guidance Cleanup levels to be based on risk, not dose… http://www.epa.gov/superfund/health/contaminants/radiation/pdfs/Rad%20Risk%20QA%20with%20transmit%20memo_June_13_2014.pdf

Hydraulic Fracturing Study Office of Research and Development/Office of Water (ORD/OW) study draft due 2016 Studying impacts of fracking on drinking water http://www2.epa.gov/hfstudy

Laboratory Methods Validation of Rapid Radiochemical Method for Gross Alpha and Gross Beta Activity Concentration in Flowback and Produced Waters from Hydraulic Fracturing Operations Issued by ORIA’s National Analytical Radiation Environmental Laboratory (NAREL) Current methods for gross alpha and gross beta are affected by high solids contents of brines http://www2.epa.gov/sites/production/files/2014-08/documents/epa-600-r-14-107_-_gross_alpha_-_gross_beta_508_km_08-08-2014.pdf

Summary The Agency continues to closely follow the issue and support states where possible. Management of TENORM varies between States. The Agency is trying to better understand the scope of the issue Some guidance documents may be useful for TENORM Not specifically developed for TENORM EPA participating in CRCPD effort States have the regulatory authority to address TENORM issues

Thank You For more information: Phil Egidi 202-343-9186 egidi.philip@epa.gov