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Comments: Acceptance of TENORM at Solid Waste & Transfer Facilities

Ohio Environmental Council, December 20, 2013

On behalf of our over 100 member environmental/conservation organizations and thousands of individual members throughout the state of Ohio, the Ohio Environmental Council (“OEC”) submits these comments to the Ohio Environmental Protection Agency (“OEPA” or “Agency”) for your consideration regarding proposed concepts for regulating the acceptance of Technologically Enhanced Radioactive Material (“TENORM”).

During the legislative debates on Ohio House Bill 59 (the Biennial Budget), which included substantive regulation of Oil and Gas related waste containing TENORM, the OEC and other organizations recommended that the General Assembly remove all provisions concerning the acceptance of shale gas waste materials into Ohio’s solid waste landfills.

It was our position that if the current administration wants to have this policy debate, it should be a fair and open debate, with separate legislation introduced appropriately analyzing and accounting for the responsibilities of the industry as well as the three state agencies with statutory responsibility over oil and gas and landfills.

This is a very complex issue, with many technical aspects, and should have been given adequate time and consultation with Ohio’s scientific community. Most importantly, public health and safety should be given priority over the need to quickly change Ohio’s solid waste laws to accommodate the shale gas industry in Ohio and the demand for shale gas waste disposal from surrounding states.

The General Assembly, however, did not heed that call.

Please click on the PDF below to read the entire comments.