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

2. 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

3. 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

4. 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
Regulatory review
Not specific to TENORM

5. 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…

6. Hydraulic Fracturing Study
Office of Research and Development/Office of Water (ORD/OW) study draft due 2016
Studying impacts of fracking on drinking water

7. 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

8. 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

9. Thank You For more information: Phil Egidi 202-343-9186