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From:
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Date:
Subj ect:
Attachm ents:

Tom.Lynch@dot.gov
"Pendergrass, Curt (CHFS DPH)" <Curt.Pendergrass@ky.gov>
3/15/2016 1:31:22 PM
RE: transportation of TENORM waste
140159.pdf

1) See the attached interp letter. No free lunch for TENORM.

2) The 10X exemption generally doesnt apply to oil and gas fracturing material as it is no longer a natural material. See interps for 173.401, especially 14-0159
http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.146906cb99fdf34f8113ae92e90d8789/?
vgnextoid=56acd3c1af814110VgnVCM1000009ed07898RCRD&vgnextchannel=56acd3c1af814110VgnVCM1000009ed07898RCRD&vgnextfmt=reg173.401&baseReg=
173&subReg=173.401
HQ responses
T Lynch
From: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]
Sent: Tuesday, March 15, 2016 11:02 AM
To: Lynch, Tom (PHMSA); Dick, Randy (PHMSA)
Subject: transportation of TENORM waste

Hello gentlemen,
I am up to my neck in technologically enhanced naturally occurring radioactive material or TENORM as they call it and the transportation and disposal of this waste from both inside and
outside KY. I read somewhere that DOT may exempt this waste since it is derived from oil and gas exploration and production, specifically hydraulic fracturing. I was just wondering if either
of you had ever encountered this issue and if so, is the slide below correct? The isotope we are dealing with in TENORM is Ra-226 and we have seen concentrations from 5 pCi/g up to
1500 pCi/g in TENORM waste transported and disposed of here in KY. None of these loads were placarded.
Thanks as always, Curt

Curt Pendergrass PhD

Supervisor, Radioactive Materials Section
Kentucky Radiation Health Branch
275 East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
E-mail: curt.pendergrass@ky.gov
Website: http://www.chfs.ky.gov/dph/radioactive.htm
Pay your fees on line at https://prd.chfs.ky.gov/rad_epay/
Be notified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
Dispose of unwanted sources http://www.crcpd.org/StateServices/SCATR.aspx

9/29/2016

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9/29/2016