OAS Meeting August 2012 Jennifer Opila (CO) and David Allard (PA)

What is ASTSWMO? Association of State and Territorial Solid Waste Management Officials Radiation Focus Group Representatives from each of the EPA Regions Broad backgrounds; Radiation Program Officials, Federal Oversight Officials, Hazardous Waste Management Officials

ASTSWMO Radiation Focus Group Mission Identify National Level Radiation Issues Coordinate State Input Partnership between State and Federal Agencies Resource to States - papers and fact sheets

Past Projects Published results of State survey regarding regulation of radioactive materials in solid waste landfills Requested ANSI standard and CRCPD SSR model regulation for radiation monitoring of solid waste 2009-Published regulator’s guide on cleanup of radiological constituents at DOD facilities Regulators who oversee cleanup of DOD facilities may not have training or experience in radiological issues

Tritium Exit Signs Paper published July 2009 Lack of Control Contamination of Landfill Leachate Recommendations: NRC evaluation of safety assessments NRC evaluation of H-3 exit signs regulations and the need for registration program

H-3 Exit Signs Petition to NRC Letter sent to NRC in November 2009 Express concern over disposal of H-3 exit signs in solid waste landfills Requests revision of regulations to improve recognition and accountability NRC issued Notice of Petition for Rulemaking in January 2010

NRC Response to ASTSWMO Petition December 2011 Petition Denied “NRC’s current regulations are adequate to protect public health and safety.” “General licensee accountability may be strengthened by enhancing regulatory guidance and improving communications between the NRC (and Agreement States) and manufacturers” NRC encourages ASTSWMO involvement in the NUREG 1556 revision

ASTSWMO Response letter Sent to NRC August 2, 2012 Pleased that NRC agreed that general licensee accountability may be strengthened by enhancing guidance and improving communication Disappointed in denial of petition to rulemaking to improve labeling and accountability. Improper disposal of exit signs in landfills increases the burden on States that regulate solid waste landfills Potential impact on groundwater If exit signs aren’t the source of the H-3 found in landfill leachate, then what is?

Technologically Enhanced NORM (TENORM) Guidance for Solid Waste Managers published April 2011 Fact Sheet-Drinking Water Treatment Residuals May 2011

Fact Sheet- TENORM Associated with Shale Gas Operations Published July 2012 Information for solid waste officials on TENORM residuals produced in shale gas operations Topics covered TENORM generation Residuals management Health and Safety Regulatory Framework

Charles Reyes, ASTSWMO Federal Facilities Staff Associate (202) , Jennifer Opila, Radiation Focus Group Chair State of Colorado Radiation Program (303) , David Allard, Commonwealth of Pennsylvania (717) ,