1. TENORM Waste Disposal CRCPD Annual Meeting Scottsdale, AZ May 8, 2017
Thank yous, etc.
My talk will focus on the waste mgt side of TENORM. Building off what we’ve learned from the previous speakers, I will provide some background and current regulatory information regarding disposal.
CRCPD Annual Meeting
Scottsdale, AZ
May 8, 2017

2. US Ecology Overview
Vision: To be the premier North American provider of environmental services where the highest caliber people work delivering sustainable solutions for our customers and long term value for stockholders and the communities in which we live and operate
Fully Integrated North American Environmental Services Provider
Unique and Irreplaceable Assets with Robust Waste Permits
Diverse, Blue Chip Customer Base across a Broad Range of Industries with over 7,000 Customers
60 + year Commitment to Health, Safety and the Environment
Strong Financial Performance
Canada
(2)
(4)
United States
Mexico
Treatment & Recycling
Disposal Sites
Service Centers
Headquarters
Retail Satellites
(2)

3. Safety and Compliance OSHA VPP Star Status at 2 Sites
USEM ISO 9001 (Quality), ISO (Environment), and OHSAS (Safety) certified
USEM celebrating 4+ years without OSHA recordable injury (>1.4M hours)
Very strong compliance record

4. USE Facility Comparison
US Ecology WAC Levels
USE Facility Comparison
WAC Parameter
USE Nevada
(RCRA-C)
USE Texas
USE
Michigan
USE Idaho
USE Washington
(NRC LLRW)
Ra-226
5 pCi/g
30 pCi/g
50 pCi/g
500 pCi/g (bulk)
1,500 pCi/g (IP-1)
10,000 pCi/g or
<1.2 Ci
Pb-210
None
150 pCi/g
260 pCi/g
1,500 pCi/g
Unlimited
K-40
TBD
818 pCi/g(1)
No Limit
Other TENORM
Tubulars
(<50 uR/hr)
MDI Downblending(2)
Ra-228
Radium Sources, etc.
Source Material (10CFR 40 or State)
< 500 ppm bulk + Exempt Items
Class A/B/C
LLRW
Byproduct Material
(10 CFR 30 or State)
Exempt Items
Exempt Items,
<3,000 pCi/g*(3)
Class A/B/C LLRW
SNM (10CFR 70)
Natural amount of K-40 in elemental potassium
Consult USEM for more information
Requires Exemption, License Termination, or Release from Regulation

5. US Ecology Michigan Permit MOD Approved by MDEQ on 12/16/16
Established formal WAC
Authorizes TENORM downblending at MDI Treatment Plant. No upper limit.

6. USEM Environmental Monitoring
On-site MDEQ inspector
Quarterly MDEQ & Wayne County inspections
7 perimeter air monitoring stations
Over 50 groundwater monitoring wells
Leachate, surface water, sediment, soil, and radon monitoring programs
Landfill leak detection monitoring by WDI and MDEQ
Regular and rigorous customer audits

7. TENORM Disposal Challenges
Not federally regulated
Up to States to regulate – Wide Disparity
Rapidly changing regulatory environment
Complex environment for generators. “It Depends…”
State Licensing of TENORM as ‘LLRW’
Politics…
Changing gears to the disposal landscape…TENORM is a challenge. The lack of uniform federal regulations leaves the individual states to regulate it as they see fit. On top of that, disposal regulations have been evolving rapidly as states attempt to keep pace with O&G activities.
The answer “it depends” is often given when I’m asked questions by generators

8. State TENORM Disposal Options
Ra-226
(pCi/g)
Notes / Basis
Nevada 5
Via State Licensing Exemption
Ohio
6.99
5 + Bkg (1.99 pCi/g)
Texas 30
Montana
15-50
Based on MDEQ 11/2015 Update
North Dakota 50
In approved ‘Special Waste’ landfills
Michigan
For all landfill types (Sub-C and -D)
Illinois
100*
Requires IEMA approval
Pennsylvania
270*
Subject to dose rate and volume limits
Colorado
Variable
From based on facility type
Idaho
1,500
At RCRA Subtitle-C landfills only
Here’s a partial list of state TENORM disposal limits (all for Ra-226). What’s most interesting about this list is how the states have arrived at their limits: some are straight licensing exemptions while others have passed legislation and/or promulgated rules to implement higher disposal limits. IL allows landfill disposal and land application with IEMA approval and other considerations. ND’s level was implemented by statute. However, I do not believe any landfills have been approved yet by NDDOH.

9. Common TENORM Wastes Drinking Water Filtration Residuals
Oil & Gas E&P/Treatment Residuals
Radium Site Cleanup Wastes
Ore and Rare-earth Processor Sites
Military Base Cleanups

10. Pop Quiz
This plot is from an unnamed site, in an unnamed state, going to one of our facilities. It shows tons of waste received over time. Can you guess by looking at the plot when regulatory enforcement actions were taken at this site? Point being…the work you do as regulators matters. Most of our generators are vigilant about following regulations and making sure their wastes are going to the appropriate places. Some, however, need some assistance.

11. Summary
If you don’t like TENORM regulations, check back in 10 minutes…
States and Industry have developed several appropriate TENORM disposal options
Ample TENORM disposal capacity
However…some states are complicated
Need to understand the disposal landscape and where your waste best fits

12. Contact Information
Joe Weismann, CHP VP, Radiological and Government Affairs (208) Chad Hyslop Director of Sales, West (208)