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Ohio Utica Shale

Ohio activists contact Kasich about radioactive drilling wastes

By Bob Downing Published: August 1, 2013

A letter to Ohio Gov. John Kasich from Ohio activists:

Ohio Governor John Kasich
Riffe Center, 30th Floor
77 South High Street
Columbus, Ohio 43215-6117
c/o Mr. Craig Butler, Environmental Liaison cc: ODNR, OEPA, ODH, OAG, media, public
Subject: Disposal of radioactive shale drilling wastes in Ohio
 
Dear Governor Kasich,
 
In a recent letter to your constituents, (find below) you asserted that Ohio is developing a comprehensive plan to address the very serious concerns related to the presence of long-lived carcinogenic radiation/radium known to be inherently present in the shale drilling waste stream. This radiation-laden waste is being disposed in our state in vast quantities through various means: injection, land filling, spraying on roads and discharge via waste water treatment plants into surface waters. To garner public trust and credibility, it is imperative that your various agencies act in a transparent and forthcoming manner, given the potential risks posed to public health, worker safety and to the environment for many years to come, long after the drilling boom has gone bust. Unfortunately, when concerned citizens have attempted to hold the agencies scientifically accountable, seeking concrete answers to even the most basic questions, those answers have not been provided to date regarding the following particularly crucial points:
 
For Ohio EPA Director Scott Nally:
 
OEPA has failed to respond to questions repeatedly posed seeking whether, in fact, OEPA has authority over TENORM radiation in drilling wastes specifically generated at waste water treatment facilities - i.e, "sludges" (as it appears it does under ORC 3701:1-43-07, Exemptions, Section J"). We ask that you please direct Ohio EPA to answer the following:
 
a) Confirm or deny OEPA has this authority. b) If OEPA indeed does have this jurisdiction over treatment plant /recycling of sludges for TENORM, we then request that OEPA provide us with all technical specifics the agency has issued/or plans to issue to landfill operators, waste generators and others, regarding what precisely OEPA is requiring to ensure there is "proper" compliance testing for the radium/uranium series, thus demonstrating the State will ultimately conduct proper management of waste potentially containing elevated levels of these sludges. (KEY: PA is reporting up to 500 times greater levels of radiation in this waste specifically due to this specific act of "treatment/recycling" ).
 
For ODNR's Chief Rick Simmers:
 
ODNR has failed to respond to reasonable questions and concerns regarding the reported disturbing usage of handheld radiation detectors/scanners being used at the Patriot/Warren facility, reportedly for each load. NOTE: According to radiation experts, this handheld detector cannot properly detect the radium of concern in water, unless the levels are very seriously high and grossly out of compliance.
 
* If handheld scanners are not adequate for proper compliance monitoring, please direct ODNR to provide citizens with a scientifically supportable explanation that can be peer reviewed, as to precisely how the State can possibly ascertain whether what is being discharged to Ohio surface waters is not exceeding the 5 pico curie limit for radiation and/ or in violation of the Clean Water Act.
 
For ODH Chief Michael Snee:
 
* To corroborate what has already been publicly asserted, please direct Ohio Dept. of Health's Bureau of Radiation Protection to confirm, in writing, that "best practices" related to radiation testing will be adhered to:
 
a) ODH confirming that the State will require truly scientifically "representative sampling" be conducted for each load prior to disposal
 
b) ODH will adhere to the same testing standard the agency had previous established when sampling the Ohio Utica Shales for radium: I.e, ODH will require each sample be held in an air tight container at a lab 21 days prior to analysis, to allow for full equilibrium of the radium's gamma daughters, thus ensuring accurate assessment of the gamma emitters at a certified laboratory.
 
Finally and perhaps most importantly, please request that one or more of the three above-mentioned agencies scientifically justify to citizens why Ohio has deliberately chosen to opt for the weaker, less protective definition/criteria regarding which drilling wastes constitute TENORM ( technically enhanced naturally occurring radiation) VS. NORM wastes. This arbitrary decision made by the State now allows a larger percentage of this highly dangerous, long lived radiation to be disposed in Ohio without any proper accountability or monitoring. It is our understanding that Ohio's less protective stance on TENORM is contrary to what the US EPA, the National Academy of Sciences and others have defined. Reportedly, even the State of Pennsylvania considers drill cuttings to be TENORM, whereas Ohio does not. Please explain how ignoring large quantities of radiation dumped into Ohio is consistent with your goal of protecting public health and carrying out a "comprehensive" management of these radioactive wastes from drilling. Moreover, please explain how allowing elevated levels of radiation to be "down blended with dirt" and then dumped into Ohio's solid waste landfills is consistent with proper management, given that these Ohio landfills are not designed to become Low Level Rad Waste Sites. Given the water solubility of radium in these wastes, this radiation could migrate through a site and enter groundwater or be collected into a landfill leachate collection system, with ultimate discharge from a city waste water plant into the surface waters of the State. In addition, what liability or risks are posed to workers involved with such down blending practices?
 
The below concerned individuals and groups from around Ohio believe the above questions and concerns are critically important in protecting public health, safety and welfare, and deserve complete answers from the State. We therefore request your immediate personal attention to this letter to ensure the public is provided this information in an expeditious manner.
 
Sincerely,
 
Chris Borello, Stark County Concerned Citizens/CCLT, Uniontown
Kathie Jones, Sandra Bilek, Concerned Citiznes of Medina County
Buckeye Forest Council
Patti & David Gorcheff, North Lima
Prof. James T. O'Reilly, College of Medicine, MPH Faculty, University of Cincinnati
Trudee Weatherby, Youngstown
Jed Thorp, Chapter Manager, Ohio Sierra Club, Columbus
John Williams, McDonald
Walter E. (Ted) Auch, PhD, Cleveland State University Faculty
Julia Fuhrman-Davis, Beaver Twp.
Vanessa Pesec, President, NEOGAP, Concord Twp.
Debra Debozy, Boardman
Greg Pace, Guernsey County Citizens Support On Drilling Issues
Joe Sirgo, Plain Twp.
Alice Marusiak, Stow, Summit Co.
Kari Matsko, Director, People's Oil & Gas Collaborative, Ohio
Jean Engle, Youngstown
Alison Auciello, Organizer, Food and Water Watch, Cincinnati
Sue Garver, Canton
Fresh Water Accountability Project
Lea Harper, Grand Rapids
Jodi Stoyak, Liberty Twp. Trustee, Trumbull County
Lynn Anderson, Youngstown
Heather Cantino, Steering Committee Member, Athens County Fracking Action Network
Diana Shaheen, Boardman
Renee Bogue, Stark County Concerned Citizens; Stark-Summit Concerned Citizens Coalition
Jenny Morgan, concerned citizen, Westerville, Franklin County
Mary C. Khumprakob, Youngstown
Elizabeth Dixon, Uniontown
Tony Paone, Plain Twp., Stark County
Judith A. & Raymond G.Vershum, Canfield
Marguerite Felice, Youngstown
Maria Montanez, Youngstown
Andrea Moore, Lowellville
Mary Greer, Concerned Citizens Ohio;Shalerville/coordinator;STAND UP OHIO/adjunct member; Ohio Organizing Collaborative/adjunct member
Heather Vahila, Lake Mohawk Property Owners Association
Jack & Joni Richards, Waynesburg, Sandy Twp.
Gwen B. Fischer, Professor Emerita Psychology Dept. Hiram College
Stan Fischer, Hiram Twp., Portage County
Elyse Hirsch, Stow Ohio, Stark- Summit Coalition
George Elias, Youngstown, Frackfree Mahoning, FANCy
Dr. Raymond Beirsdorfer, Professor of Geological & Environmental Sciences, YSU
Susie Beirsdorfer, Frackfree Mahoning
Dan & Beverly Seiple, North Canton
Lori Babbey, Concerned Citizens Ohio, Portage County
Melanie Roll, concerned citizen, North Canton
 
.........................
Below is the Governor's letter sent in June to an Ohio concerned citizen for reference:
---------- Forwarded message ----------
From: Governor John Kasich <Intranet.Quorum@governor.ohio.gov>
Date: Wed, Jun 26, 2013 at 5:02 PM
Subject: Reply from Governor John Kasich
To:
Dear Renee:
 
Thank you for contacting the Governor regarding fracking regulations in the proposed executive budget. We appreciate hearing from you.
 
As drilling activities in the Marcellus and Utica Shale formations have developed in Pennsylvania and Ohio, the volumes of waste have increased significantly and are expected to increase in the future.
 
Some of the waste streams resulting from drilling activities are defined as Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) that may contain elevated levels of radium-226 and radium-228. This waste stream may include tank bottoms, spent drilling fluids, or other waste streams.
 
Ohio is proactively strengthening its regulatory programs with this proposed budget language to ensure public safety and environmental protection by requiring the wastes to be properly tested, managed, and disposed.
 
Ohio Departments of Health, Natural Resources, and Environmental Protection have worked together to develop a comprehensive and sensible system that will protect public health and safety. For any questions on this topic please do not hesitate to contact the offices listed below:
 
The ODNR Division of Oil and Gas Resources can be reached at (614) 2656922.
 
The EPA Division of Material and Waste Management can be reached at (614) 644-2621.
 
The ODH Nuclear Materials Safety office can be reached at (614) 644-2727.
 
As always, please feel free to call our office at (614) 644-4357. Thank you.
 
 

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