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.
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….
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.…
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?
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
CC: NCTCA Group
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?