US DOT = 7 mths response on NORM vs TENORM truck fracking exemptions

Here is a link of a response from the US Dept Of Transportation when asked by a trucking company to verify if TENORM is “oil & gas waste exempt” from regulation like NORM is.

It took US DOT seven months to respond back…the trucker guy that asked was doing his job in trying to find out which “rules of the road” he needs to follow.

Screen shot 2014-11-19 at 11.54.56 PM Screen shot 2014-11-19 at 11.55.17 PM

http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_8C01D0DAB56FACCA278444DE4C69446DC8BE0000/filename/130157.pdf

Hell I’m almost scared to post this blog for fear that exempting TENORM will get added in next the legislative session now that I’ve brought this up…..now HOW DO I ENSURE THAT  all the truck fracking traffic truck driving guys understand that any phase of the oil & gas extraction processes that changes NORM to TENORM….is actually…..drum roll please….. R E G U L A T E D.

Here is the link to the actual radionuclides list and threshold amounts….

https://www.gpo.gov/fdsys/pkg/CFR-2009-title49-vol2/pdf/CFR-2009-title49-vol2-sec173-436.pdf

 

In the letter, it looks like Mr Dawson had to wait over half a year on US DOT to get an answer to what should have been a rather pressing question (in wanting to see how far the fracking related federal exemptions reach)…..not that   *NORM  isn’t harmless…..but guess trickydick Cheney forgot to write in the TENORM exemption when they exempted NORM.

….the saltier the brine, the more radioactive it is….ooops

So if TENORM isn’t exempt (like NORM is) from USDOT consignments/truck fracking that waste around, what is the significance to this?

How can we find out if they have been in compliance?

Looks like THEY are worried too about waste reclassification causing nonexempt status…..looks like they may have been NONcompliant from the get go?

Here is some info on our NORM and TENORM risk in Arlington Gasland TX.

Here is a very troubling statement made here http://ehp.niehs.nih.gov/122-a50/#r32.“Although there are few empirical data available, the natural gas industry has not been concerned about radon reaching its consumers in significant amounts, in part because of radon’s short half-life and because much of it is released to the atmosphere at the wellhead.” 

Happy breathing, eating, and drinking in our “god blessed us?” shale….ain’t it good to know the frackers have to eat & drink like us too?

From: Kim Feil
To: jpoweres@nrdc.org

CC: NCTCA Group

ArlingtonConservationCouncil@yahoogroups.com

Jim Fuquay, jim.parajon@arlingtontx.gov, don.crowson@arlingtontx.gov,
Today at 12:56 PM

I noticed that http://texasalliance.org/txdot-begins-saltwater-row-regulations/ article references the injection well classifications and how it relates to seismic concerns/controls, but please clarify if the classifications pertain to whether…

1) when brine is treated it is not natural anymore and therefore not exempt and maybe should have been going into more regulated Class I wells instead of the less regulated Class II wells?

2) or if the classification being referenced for treated brine (therefore not exempt) should also include the txdot truck consignment/shipping of the waste. Should there have been TRUCK MANIFESTS (verses less regulated trip trick tickets) and appropriate hazmat truck signage mandates along with water test results all along?

3) Is the term NORM or TENORM related to this txdot regulations review effort now that I found this document/letter where usdot recognizes non exempt status?

I need to understand if the industry has incorrectly assumed exempt status, or if there is a review effort to “correct” this exempt status?

If you read my blog, I had an issue with USDOT taking 7 months to respond to this trucking waste hauling company…but now I’m just plain ol interested in how the NRDC can assist with finding out if all along this TENORM related waste being driven around should have not been exempt and if the trucks shipping it around should have been measuring the radionuclides all this time?

Maybe they have been measuring the radionuclides because even the exempt NORM becomes nonexempt when it goes ten times the recommended amount….how do we know if they measured in the first place?

Kim Feil
https://barnettshalehell.wordpress.com/

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About Kim Triolo Feil

Since TX Statute 253.005 forbids drilling in heavily settled municipalities, I unsuccessfully ran for City Council Seat to try to enforce this. Since Urban Drilling, our drinking water has almost tripled for TTHM's. Before moving to Arlington in 1990, I lived in Norco’s “cancer alley”, a refinery town. It was only after Urban Drilling in Arlington did I start having health effects. After our drill site was established closest to my home, the chronic nosebleeds started. I know there are more canaries here in Arlington having reactions to our industrialized airshed (we have 55-60 padsites of gas wells). Come forward and report to me those having health issues especially if you live to the north/northwest of a drill site so I can map your health effects on this blog. My youtube account is KimFeilGood. FAIR USE NOTICE: THIS SITE MAY CONTAIN COPYRIGHTED MATERIAL THE USE OF WHICH HAS NOT ALWAYS BEEN SPECIFICALLY AUTHORIZED BY THE COPYRIGHT OWNER. MATERIAL FROM DIVERSE AND SOMETIMES TEMPORARY SOURCES IS BEING MADE AVAILABLE IN A PERMANENT UNIFIED MANNER, AS PART OF AN EFFORT TO ADVANCE UNDERSTANDING OF THE SOCIAL JUSTICE ISSUES ASSOCIATED WITH EMINENT DOMAIN AND THE PRIVATIZATION OF PUBLIC INFRASTRUCTURE (AMONG OTHER THINGS). IT IS BELIEVED THAT THIS IS A 'FAIR USE' OF THE INFORMATION AS ALLOWED UNDER SECTION 107 OF THE US COPYRIGHT LAW. IN ACCORDANCE WITH TITLE 17 USC SECTION 107, THE SITE IS MAINTAINED WITHOUT PROFIT FOR THOSE WHO ACCESS IT FOR RESEARCH AND EDUCATIONAL PURPOSES. FOR MORE INFORMATION, SEE: HTTP://WWW.LAW.CORNELL.EDU/ TO USE MATERIAL REPRODUCED ON THIS SITE FOR PURPOSES THAT GO BEYOND 'FAIR USE', PERMISSION IS REQUIRED FROM THE COPYRIGHT OWNER INDICATED WITH A NAME AND INTERNET LINK AT THE END OF EACH ITEM. (NOTE: THE TEXT OF THIS NOTICE WAS ALSO LIFTED FROM CORRIDORNEWS.BLOGSPOT.COM)
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