Emails Volume I

Dr.
George Partridge
Energy & Environmental Cabinet
Emails Volume I
GP001
Partridge, George (EEC)
II!~:
To:
Cc:
Subject:
Kevin Kosko <kevink@shalemtr.com>

Wednesday, January 13, 2016 3:12 PM
David Patrick
Conversation
George,
Thank you for taking the time to talk with me today regarding TENO RM disposal regulations in the state of Ky. You will
also probably be getting a call from Leo Guzmondi from Nuverra regarding this issue. It was ironic as I called him about
taking their waste from several brine recycling facilities in Ohio and PA. He stated that they were planning to take the 810 boxes (15 tons/box) that they produce daily to KY for disposal. I told him of our discussion and KRS 211.863 and he
was completely unaware of the statute. The waste from those facilities and others similar (that currently take waste to
KY) typically range from 300-600 pCi/g for Radium-226 and Radium-228. This is not only a significant concentration from
a worker/environmental protection standpoint (Ohio allows 6.99 pCi/g, North Dakota and Michigan allow 50 pCi/g) but
compliant transportation of this material also requires DOT Radioactive LSA labeling or Class 7 Radioactive Material
placarding. I am not sure how the good people of Kentucky will feel about seeing placarded loads of radioactive material
going to local landfills.
This seems to be a similar situation that WV. was in about a year ago. The majority of TENO RM waste rejected at PA and
Ohio landfills was going to WV., when the press found out what was happening the backlash was so severe the governor
...rlacted emergency legislation to place a moratorium on TENORM disposal in all state landfills.
~ase feel free to contact me if you would like.

Respectfully,
Kevin
Kevin Kosko
Vice President
Compliance/Regulatory Affairs
Shale Mountain Resources
Phone: {937) 470-2655
SHALE MOUNTAIN
R E S 0 U R C E S
Protect the future, recycle the past ...
GP002
To:
Cc:
Subject:
Kevin Koska <kevink@shalemtr.com>

Monday, January 18, 2016 8:54 AM
David Patrick
RE: Conversation
George,
It was very nice to hear back from you so quickly regarding this subject. After our conversation, I also spoke with Jason
Frame who is the Director of the WV Bureau of Radiation Protection regarding their impending regulations. The topic of
TRNORM disposal in KY came up and I forwarded the applicable regulation (KRS 211.863) that you sent to him. Jason is
another proactive regulator who is aware of incidences where high concentration (>600 pCi/g) waste was sent to a KY
landfill because the waste could not legally be disposed in WV or PA. I hope you don't mind but I gave him your contact
information and he said he would be giving you a call. As you are aware, WV was the last state in the region not to have
regulations for TE NORM disposal. Out of state dumping got so bad the Governor had to enact emergency legislation to
stop it until formal laws could be drafted.
Please let me know if I can ever be of assistance.
Respectfully,
9vin
"evi n Kesko
Vice President
Phone: (937) 470-2655
SHALE MOUNTAIN
R E S 0 U R C E S
From: Partridge, George (EEC) [mailto:George.Partridge@ky.gov]

Sent: Friday, January 15, 2016 7:55 PM
To: Kevin Kosko <kevink@shalemtr.com>
Subject: RE: Conversation
Thank you for contacting our Solid Waste Branch. It was a pleasure to speak to you over the phone concerning a topic I
have been concerned about and involved with for several years now.
1
GP003
Since we received two phone calls this week regarding TENO RM, the Director ofthe Division of Waste Management has
requested our Program Planning and Administration Branch to work with me to get familiar with TENORM and to look
how we need to respond here in Kentucky. This effort was initiated as a result of your phone call. I did not share
names, specifics, but only indicated in general terms that if we ignore taking a position on TENO RM, we will be
witnessing its disposal in landfills designated for other types of waste.
Please continue to stay in touch as you learn more.
I want an opportunity to identif'f' a situatio_nand use that to help establish the need for Kentucky to develop_g regulatory
or policy framework while being sensitive to all parties involved, including landfill management or companies that may
not recognize or understand what they are facing as well as those like yourself that share important information we
need to work toward proper management of waste disposal.
Thanks again for being so generous with you time and sharing all that you did with me.
Please do not hesitate to call or email me anytime.
I look forward to this coming week to continuing my work on TENO RM with other members of our Division.
George
George P. Partridfje Jr., Pli'D, P.'E., Q'EP

Department for Environmental Protection
KY Division of Waste Management
200 Fair Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
'
From: Kevin Kosko [mailto:kevink@shalemtr.com]

Sent: Wednesday, January 13, 2016 3:12 PM
To: Partridge, George (EEC)
Cc: David Patrick
Subject: Conversation
George,
was completely unaware of the statute. The waste from those facilities and others similar (that currently take waste t o .
KV) typically range from 300-600 pCi/g for Radium-226 and Radium-228. This is not only a significant concentration fro 1
2
GP004
s seems to be a similar situation that WV. was in about a year ago. The majority of TE NORM waste rejected at PA and
io landfills was going to WV., when the press found out what was happening the backlash was so severe the governor
enacted emergency legislation to place a moratorium on TENORM disposal in all state landfills.
Please feel free to contact me if you would like.
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
f '"'
SHALE MOUNTAIN
R E S 0 U R C E S
the future, recyde the P"' ..
Spam
Phi sh/Fraud
Not spam
Forget previous vote
I
GP005
-m:
Subject:

Tuesday, January 19, 2016 8:22 AM
Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Hatton, Tony (EEC)
RE: TENORM in Landfills in Kentucky
Tracking:
Recipient
Delivery
Briggs, Lindsey (EEC)
Delivered: 1/19/2016 8:22 AM
Anderson, Danny J (EEC)
Delivered: 1/19/2016 8:22 AM
Read: 1/19/2016 8:49 AM
Hatton, Tony (EEC)
Delivered: 1/19/2016 8:22 AM
Read: 1/19/2016 8:32 AM
Sent:
To:
Read
Lindsey, Danny, and Tony;

I am being contacted about TENO RM that is headed for Kentucky or already has been disposed of in landfills in Kentucky
that includes:
150 tons of 300-600 pCi/g Radium-226 and Radium-228 waste from Ohio and PA.
> 600 piC/g waste from WV/PA.
I was contacted again this week. I am also expecting a call from Director of the WV Bureau of Radiation Protection who
is proactively addressing the situation. WV has impending regulations to address TENORM disposal. Out of state
.amping got s.o bad the Governor enacted emergency legislation to stop it until formal laws could be drafted. With
r i o , WV, PA and other states moving forward with regulations, waste is now being diverted to Kentucky.
I have been corresponding with Dr. Curt Pendergrass, Supervisor of the Radioactive Materials Section for the Kentucky
Radiation Health Branch (DPH) for several years now and we exchange information and experiences. We both see the
need for Kentucky to move forward with addressing TENO RM waste disposal since our state will become a dumping
ground as it becomes more costly or prohibited to dispose of TENO RM in other states.
I will glad to support and work on initiatives for Kentucky to protect the safety of employees at our landfills as well as
protect the environment. My concern is that TENO RM waste may be received by landfills that are not aware of its
radioactive nature.
Thank you for the opportunity to share my concerns.
Best wishes to you all for a nice week!
George
(jeorae P. PartridfJe Jr., Pfi'D, P.'E., Q'EP

KY Division of Waste M9-nagement
Frankfort, KY 40601
. .2) 564-6716 ext. 4651
GP006
GP007
-m:
To:
Sent:
Subject:
Hatton, Tony (EEC)

Read: RE: TENORM in Landfills in Kentucky
Your message
To: Hatton, Tony (EEC)
Subject: RE: TENORM in Landfills in Kentucky
Sent: Tuesday, January 19, 2016 8:21 :58 AM (UTC-05:00) Eastern Time (US & Canada)
was read on Tuesday, January 19, 2016 8:32:07 AM (UTC-05:00) Eastern Time (US & Canada).
GP008
--om:
To:
Sent:
Subject:

Read: RE: TENORM in Landfills in Kentucky
Your message
To: Anderson, Danny J (EEC)
Sent: Tuesday, January 19, 2016 8:21 :58 AM (UTC-05:00) Eastern Time (US & Canada)
was read on Tuesday, January 19, 2016 8:48:46 AM (UTC-05:00) Eastern Time (US & Canada).
GP009
-m:
Sent:
To:
Subject:

'Kevin Koska'
RE: Conversation
Kevin;
Thank you for the additional information regarding TENORM. I am glad you shared my contact information with others
that are addressing TENORM. To date, all I have done is indicate to my management, including the Direction of the
Division of Waste Management that we are receiving contacts indicating that there are plans to either dispose of
TENO RM at landfills in Kentucky or that waste has already been received. I have not mentioned any names or specifics
since my goal only at this point is to bring to management's attention the increasing concern we have about the proper
management of TE NORM.
I am pleased to share that our Division Director, Tony Hatton has assigned someone who is involved in policy
development to take a look at TENO RM and to work with me on this important topic. They plan to get with me this
week.
I will do all I can as a technical person in the Division of Waste Management to support addressing this important issue.
Thank you again for corresponding with me and encouraging correspondence with others that are working on TENORN
,,posal.
Have a nice week!
George
(jeorge P. PartridiJe Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
Sent: Monday, January 18, 2016 8:54 AM

Cc: David Patrick
.....jfiect: RE: Conversation
-::orge,
GP010
It was very nice to hear back from you so quickly regarding this subject. After our conversation, I also spoke with Jason
Frame who is the Director of the WV Bureau of Radiation Protection regarding their impending regulations. The topic of
TRNORM disposal in KY came up and I forwarded the applicable regulation (KRS 211.863) that you sent to him. Jason is
another proactive regulator who is aware of incidences where high concentration (>600 pCi/g) waste was sent to a KY , . .
landfill because the waste could not legally be disposed in WV or PA. I hope you don't mind but I gave him your contact
information and he said he would be giving you a call. As you are aware, WV was the last state in the region not to have
regulations for TENO RM disposal. Out of state dumping got so bad the Governor had to enact emergency legislation to
stop it until formal laws could be drafted.
A..
__
. _E.leaseJetme_kno_lllLif_l_can_e_v.eLb.e_of_assistance."-~~---._.-----~-------------~---~~Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
SHALE MOUNTAIN
R E S 0 U R C E S

Kevin;
Since we received two phone calls this week regarding TENO RM, the Director of the Division of Waste Management has
requested our Program Planning and Administration Branch to work with me to get familiar with TENO RM and to look at
names, specifics, but only indicated in general terms that if we ignore taking a position on TE NORM, we will be
I want an opportunity to identify a situation and use that to help establish the need for Kentucky to develop a regulatory.
GP011
fl'anks again for being so generous with you time and sharing all that you did with me.
George

Cc: David Patrick
George,
Thank y.ou for taking the time to talk with me today regarding TENORM disposal regulations in the state of Ky. You will
taking their waste from several brine recycling facilities in Ohio and PA. He stated that they were planning to take the 8~ boxes (15 tons/box) that they produce daily to KY for disposal. I told him of our discussion and KRS 211.863 and he
~s completely unaware of the statute. The waste from those facilities and others similar (that currently take waste to
This seems to be a similar situation that WV. was in about a year ago. The majority of TE NORM waste rejected at PA and
Please feel free to contact me if you would_like.
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
GP012
SHALE MOUNTAIN
R E S 0 U A C E S
Protect the future, recycle the past...
Spam
Phi sh/Fraud
Not spam
GP013
-m:
Sent:
To:
Subject:

Pendergrass, Curt (CHFS DPH)
FW: RE: TENORM in Landfills in Kentucky
Curt:
I have been getting contacted about TE NORM disposal in Kentucky recently (two contacts this past week) and follow-up
contacts.
I am being told that TENO RM waste is being disposed of and/or planned for disposal in Kentucky by out of state
individuals.
'
This morning I sent the following message to my Supervisor (Lindsey Briggs - Permitting Section), my Branch Manager
(Solid Waste Branch) Danny Anderson, and to Tony Hatton (Director of the Division of Waste Management).
We have been in contact for several years now and have conveyed our concerns to our respective management. I have
researched the topic, looked at what other states are doing, and have proposed a regulatory framework- but still
waiting on a response regarding the next step.
I hope it will not be too long before we can meet as a group to discuss TE NORM and how we should approach regulating
~disposal in Kentucky.
Look forward to us keeping in touch!
Have a nice week!
George
(jeorge P. Partrirfge Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
From: Partridge, George (EEC)
Sent: Tuesday, January 19, 2016 8:22 AM
.lj= Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Hatton, Tony (EEC)
pbject: RE: TENORM in Landfills in Kentucky
1
GP014
that includes:
is proactively addressing the situation. WV has impending regulations to address TENORM disposal. Out of state
dumping got so bad the Governor enacted emergency legislation to stop it until formal laws could be drafted. With
~~--J1hLo,_W~,J>A_and~o_tberstates_mo_\LiogJoL1&ar_d_withLegulatLor1s,_was_teJsno_w_b_eJng_dL\Lerte_dto_Kentucky~-~----~~-~---~---~~-
radioactive nature.
George
GP015
~is seems to be a similar situation that WV. was in about a year ago. The majority of TENO RM waste rejected at PA and
~~io landfills was going to WV., when the press found out what was happening the backlash was so severe the governor
Respectfully,
Kevin
Kevin Kesko
Vice President
Phone: (937) 470-2655
SHALE ....
'LO......
R E S 0 U R
E S
"ot<cl the futme, cycle the P"' ..
Spam
Phish/Fraud
Not spam
,,,
3
GP016
.A_m
-=.t:
To:
Subject:
Harris, Marc <marc.harris@aecom.com>

Monday, January 25, 2016 12:57 PM
Sandblasting Grit - NORM waste handling
George,
Per our phone conversation, here is my contact information. Please send me references to an regulations that Kentucky
currently has regarding low level NORM waste. As we discussed, my client will copy you on any correspondence with
Curt Pendergrass when disposal of spend blasting grit becomes necessary.
Thanks again for your assistance.
Marc Harris
Senior Geologist/Project Manager
AECOM
525 Vine St, Suite 1800
Cincinnati, OH 45202
Office: 513-419-3411
Cell: 513-659-4579
GP017
-m:
Sent:
To:
Subject:

'Harris, Marc'
RE: Sandblasting Grit - NORM waste handling
Marc;
Thank you for your call today. I appreciate being copied on correspondence with Curt Pendergrass since we both have
been addressing the NORM/TE NORM over the last several years.
I have inserted below the regulations we have been looking at here in Kentucky that are related or potentially could be
related to this type waste. The first two: KRS 211.862 and KRS 211.863 are the ones that I feel are of most interest to
you at this point. The others are more general, but may have some relevance as we move forward with a regulatory
framework for Kentucky.
Thank you again for your phone call.
George
<jeorne P. PartridiJe Jr., PhD, P.E., QEP

~Y Division of Waste Management
~o
Fair Oaks Lane; 2nd Floor (SWB)

Frankfort, KY 40601
(502) 564-6716 ext. 4651
Kentucky Revised Statues:

211.862 Definitions for KRS 211.861 to 211.869
"Commission" means the Central Midwest Interstate Low-Level Radioactive Waste Commission.
(8) "Naturally-occurring radioactive material" (NORM) means naturally occurring materials not regulated
under the Atomic Energy Act of 1954, as amended, whose radionuclide concentrations have been
increased by or as a result of human practices. Naturally occurring radioactive material does not
include the natural radioactivity of rocks, or soils, or background radiation, but instead refers to
material whose radioactive is technologically enhanced by controllable practices (or by past human
practices).
(10) "Region" means the geographical area of the state of Illinois and the Commonwealth of Kentucky.
(1)
211.863 Control of commerce of low-level radioactive waste in and out of Kentucky - Prohibitions Exemption
1
GP018
(3) Naturally-occurring radioactive material (NORM) as defined in KRS 211.862(8) shall be the exclusive
regulatory responsibility of the states, except that no person shall import naturally occurring radioactive A..
material (NORM) from outside the region for disposal in Kentucky, or dispose of such imported
~
material in Kentucky, if the imports or disposal are inconsistent with policies of the commission.
increased by or as a result of human practices. Naturally occurring radioactive material does not include
the natural radioactivity of rocks or soils, or background radiation, but instead refers to materials whose
----------rad-ioaetivity-is-teehnolog-ieaHy-enhaneed-by-e0ntrnUable-prae-tie-es-E0r-by~humanpF-ae-t-ieesj.
224.1-100 Reportable quantities and release notification requirements for hazardous substances,
pollutants, or contaminants - Variation of requirements by administrative regulations - Emergency plan
- Powers of the cabinet - Remedial action to restore environment - Lien of cabinet for costs of cleanup Liability of financial institution acquiring property or serving as fiduciary.
(18) Any person possessing or controlling a hazardous substance, pollutant, or contaminant which is released to
the environment, or any person who caused a release to the environment of a hazardous substance, pollutant, or
contaminant, shall characterize the extent of the release as necessary to determine the effect of the release on the
environment, and shall take actions necessary to correct the effect of the release on the environment. Any
person required to take action under this subsection shall have tht:1 following options:
(a) Demonstrating that no action is necessary to protect human health, safety, and the environment;
(b) Manage the release in a manner that controls and minimizes the harmful effects of the release and
protects human health, safety, and the environment, provided that the management may include any
existing or proposed engineering or institutional controls and the maintenance of those controls;
(c) Restoring the environment through the removal of the hazardous substance, pollutant, or contaminant; or
(d) Any combination of paragraphs (a) to (c) of this subsection.
224.46-530 Specific authority of cabinet over management of hazardous wastes.(l)(k) To regulate

hazardous waste that is radioactive except to the extent that such waste is source, special nuclear or byproduct material as defined by the Atomic Energy Act of 1954, as amended, (68 Stat. 923);
~24.50-760
Special waste -Exemptions from KRS 224.46-510 and 224.46-520- Permit-Notice- Hearing
(l)(a) For the purposes of this section and KRS 224.46-580(7), special wastes are those wastes of high volume
and low hazard which include but are not limited to mining wastes, utility wastes (fly ash, bottom ash, scrubber
sludge), wastes from coal gasification facilities (vitrified coarse solid residues, prilled or blocked sulfur)
approved by the cabinet based on submittal of appropriate testing demonstrating that the wastes are of low
hazard, sludge from waste treatment facilities and wastewater treatment facilities, cement kiln dust, gas and oil
drilling muds, and oil production brines. Other wastes may be designated special wastes by the cabinet;
Kentucky Administrative Regulations:

Title 401 Energy and Environment Cabinet - Department for Environmental Protection
401KAR45:010. Definitions for 401 KAR Chapter 45
Section 1. Definitions (1) "Beneficial reuse" means the use or reuse of special wastes, other than solids, residue~
and precipitate separated from or created in sewage from humans, households, or commercial establishments by~
the processes of a wastewater treatment plant which are subject to the provision of 401 KAR 45: 100, in a
2
GP019
manner that complies with the environmental performance standards 401 KAR 30:301 and all other applicable
requirements of 401 KAR Chapter 45.
, , 6 ) "Special waste" is defmed by KRS 224.50-760(l)(a).

Title 902; Cabinet for Health and Family Services - Department for Public Health; Chapter 100 Radiology, 019
Standards for Protection Against Radiation
902 KAR 100:019 Section lO(l)(a) states, in part that the " ... total effective dose equivalent [TEDE] to
individual members of the public from licensed, registered, and other operations shall not exceed one-tenth
(0.1) rem (one (1) mSv) in a year... "
902 KAR 100:019 Section 2(4)(a) states that doses from air emissions of radioactive material to the
environment (excluding radon-222 and its daughters) to the member of the public likely to receive the highest
dose, " ... will not be expected to receive a total effective dose equivalent in excess often (10) millirems (0.1
mSv) per year from these emissions. "
902 KAR 100:042 Section 2(1) states that a site shall be considered acceptable for unrestricted use if (a) "(t)he
residual radioactivity that is distinguishable from background radiation results in a TEDE to an average
member of the critical group that does not exceed twentyjive (25) millirem (0.25 mSv) per year, including
radioactivity from groundwater sources of drinking water... " and (b) if "(t)he residual radioactivity has been
reduced to ALARA levels."
902 KAR 100:042Section1(4) states that "(w)hen calculating TEDE to the average member of the critical
.oup, the licensee shall determine the peak annual TEDE dose expected within the first 1000 years after
ri:commissioning. "
From: Harris, Marc [mailto:marc.harris@aecom.com]
Sent: Monday, January 25, 2016 12:57 PM

Subject: Sandblasting Grit - NORM waste handling
George,
Marc Harris
Senior Geologist/Project Manager
AECOM
Cincinnati, OH 45202
Office: 513-419-3411
# I I : 513-659-4579
GP020
Harris, Marc <marc.harris@aecom.com>

RE: Sandblasting Grit - NORM waste handling
Subject:
Thanks George

To: Harris, Marc
Subject: RE: Sandblasting Grit - NORM waste handling
Marc;
Thank you for your call today. I appreciate being copied on correspondence with Curt Pendergrass since we both have
been addressing the NORM/TENO RM over the last several years.
I have inserted below the regulations we have been looking at here in Kentucky that are related or potentially could be
related to this type waste. The first two: KRS 211.862 and KRS 211.863 are the ones that I feel are of most interest to
you at this point. The others are more general, but may have some relevance as we move forward with a regulatory
framework for Kentucky.
- n k you again for your phone call.
George
<;ieorge P. Partrid{Je Jr., PhD, P.E., QEP

200 Fair Oaks Lane; 2n,d Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
Kentucky Revised Statues:

211.862 Definitions for KRS 211.861 to 211.869
-(1)
(8)
"Commission" means the Central Midwest Interstate Low-Level Radioactive Waste Commission.
"Naturally-occurring radioactive material" (NORM) means naturally occurring materials not regulated
increased by or as a result of human practices. Naturally occurring radioactive material does not
1
GP021
include the natural radioactivity of rocks, or soils, or background radiation, but instead refers to
material whose radioactive is technologically enhanced by controllable practices (or by past human
practices).
( 10) "Region" means the geographical area of the state of Illinois and the Commonwealth of Kentucky.
L
~
211.863 Control of commerce of low-level radioactive waste in and out of Kentucky - Prohibitions Exemption
(3) Naturally-occurring radioactive material (NORM) as defined in KRS 211.862(8) shall be the exclusive
regulatory-responsibilityufthe~states~except-that-no-persoffshalhmport-naturaHy-occurring-radioactive
material (NORM) from outside the region for disposal in Kentucky, or dispose of such imported
material in Kentucky, if the imports or disposal are inconsistent with policies of the commission.
increased by or as a result of human practices. Naturally occurring radioactive material does not include
the natural radioactivity of rocks or soils, or background radiation, but instead refers to materials whose
radioactivity is technologically enhanced by controllable practices (or by human practices).
-~~
224.1-100 Reportable quantities and release notification requirements for hazardous substances,
pollutants, or contaminants - Variation of requirements by administrative regulations - Emergency plan
- Powers of the cabinet - Remedial action to restore environment - Lien of cabinet for costs of cleanup Liability of financial institution acquiring property or serving as fiduciary.
(18) Any person possessing or controlling a hazardous substance, pollutant, or contaminant which is released to
the environment, or any person who caused a release to the environment of a hazardous substance, pollutant, or,A..
contaminant, shall characterize the extent of the release as necessary to determine the effect of the release on th~
environment, and shall take actions necessary to correct the effect of the release on the environment. Any
person required to take action under this subsection shall have the following options:
(a) Demonstrating that no action is necessary to protect human health, safety, and the environment;
(b) Manage the release in a manner that controls and minimizes the harmful effects of the release and
protects human health, safety, and the environment, provided that the management may include any
existing or proposed engineering or institutional controls and the maintenance of those controls;
(c) Restoring the environment through the removal of the hazardous substance, pollutant, or contaminant; or
(d) Any combination of paragraphs (a) to (c) of this subsection.
224.46-530 Specific authority of cabinet over management of hazardous wastes.(l)(k) To regulate

hazardous waste that is radioactive except to the extent that such waste is source, special nuclear or byproduct material as defined by the Atomic Energy Act of 1954, as amended, (68 Stat. 923);
224.50-760 Special waste -Exemptions from KRS 224.46-510 and 224.46-520- Permit-Notice - Hearing
(l)(a) For the purposes of this section and KRS 224.46-580(7), special wastes are those wastes of high volume
and low hazard which include but are not limited to mining wastes, utility wastes (fly ash, bottom ash, scrubber
sludge), wastes from coal gasification facilities (vitrified coarse solid residues, prilled or blocked sulfur)
approved by the cabinet based on submittal of appropriate testing demonstrating that the wastes are of low
hazard, sludge from waste treatment facilities and wastewater treatment facilities, cement kiln dust, gas and oil
drilling muds, and oil production brines. Other wastes may be designated special wastes by the cabinet;
_,,
Kentucky Administrative Regulations:

2
GP022
Title 401 Energy and Environment Cabinet - Department for Environmental Protection
401KAR45:010. Definitions for 401 KAR Chapter 45
f!/lction 1. Definitions (1) "Beneficial reuse" means the use or reuse of special wastes, other than solids, residues
and precipitate separated from or created in sewage from humans, households, or commercial establishments by
the processes of a wastewater treatment plant which are subject to the provision of 401 KAR 45: 100, in a
manner that complies with the environmental performance standards 401KAR30:301 and all other applicable
requirements of 401 KAR Chapter 45.
(16) "Special waste" is defined by KRS 224.50-760(1)(a).
Title 902; Cabinet for Health and Family Services -Department for Public Health; Chapter 100 Radiology, 019
Standards for Protection Against Radiation
902 KAR 100:019 Section lO(l)(a) states, in part that the " ... total effective dose equivalent [TEDE] to
individual members of the public from licensed, registered, and other operations shall not exceed one-tenth
(0.1) rem (one (1) mSv) in a year... "
902 KAR 100:019 Section 2(4)(a) states that doses from air emissions of radioactive material to the
environment (excluding radon-222 and its daughters) to the member of the public likely to receive the highest
dose, " ... will not be expected to receive a total effective dose equivalent in excess often (JO) millirems (0.1
mSv) per year from these emissions. "
902 KAR 100:042 Section 2(1) states that a site shall be considered acceptable for unrestricted use if (a) "(t)he
radioactivity that is distinguishable from background radiation results in a TEDE to an average
~mber of the critical group that does not exceed twenty-five (25) millirem (0.25 mSv) per year, including
radioactivity from groundwater sources of drinking water... " and (b) if " (t )he residual radioactivity has been
reduced to ALARA levels."
~idual
902 KAR 100:042 Section 1(4) states that "(w )hen calculating TEDE to the average member of the critical
group, the licensee shall determine the peak annual TEDE dose expected within the first 1000 years after
decommissioning. "
From: Harris, Marc [mailto:marc.harris@aecom.com]

Subject: Sandblasting Grit - NORM waste handling

George,
Marc Harris
9ior Geologist/Project Manager
.AECOM
3
GP023
To:
Cc:
Subject:

Wednesday, January 27, 2016 11:03 AM
David Patrick
RE: Conversation
George,
I am writing to inform you that the amount of high concentration TE NORM waste being imported into Ky. for disposal is
larger than I originally thought. Just today, one of my salesman visited three facilities in Norwich Ohio that are taking all
of their TENORM waste (that is too highly concentrated to enter or that has been rejected by Ohio, PA, and/or WV)
to Advanced Waste's Green Valley Facility located in Ashland, Ky. Based on the regulation you sent (KRS 211.863) this is
seemingly prohibited. The generators are being told that this is a legal disposal option by the landfill facility. Is this
correct? Is the Advanced Waste Landfill facility truly a legal disposal option for highly concentrated TENORM generated
outside of the region (KY and Illinois)? If so we would like to start sending the mass quantities of waste we have to that
facility instead of the specially constructed radioactive waste landfill where we currently send it.
Respectfully,
Kevin
tlevin Kosko
Vice President
Phone: (937) 470-2655
SHALE MOUNTAIN
R E S 0 U R C E S
:e!m:
'
Partrid.ge, George (EEC) [mailto:George.Partridge@ky.gov]
. t: Friday, January 15, 2016 7:55 PM
To: Kevin Koska <kevink@shalemtr.com>

GP024
Kevin;
Thank you for contacting our Solid Waste Branch. It was a pleasure to speak to you over the phone concerning a topic
'A..
'W
requested our Program Planning and Administration Branch to work with me to get familiar with TENORM and to look at
~---_wjtnessingits_dis.p.osaUn_ landfiUs.1.esignateclfoLother:..ty.p_es_of.waste-~----~-----------~---._.. _________
. --~--~-~--Please continue to stay in touch as you learn more.
I want an opportunity to identify a situation and use that to help establish the need for Kentucky to develop a regulatory
George
(ieorge P. PartridiJe Jr., Pli'D, P.T., Q,TP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Cc: David Patrick
George,
a...
also probably be getting a call from Leo Guzmondi from Nuverra regarding this issue. It was ironic as I called him about ~
2
GP025
KV) typically range from 300-600 pCi/g for Radium-226 and Radium-228. This is not only a significant concentration from
~rker/environmental protection standpoint (Ohio allows 6.99 pCi/g, North Dakota and Michigan allow 50 pCi/g) but
.::~pliant transportation of this material also requires DOT Radioactive LSA labeling or Class 7 Radioactive Material
This seems to be a similar situation that WV. was in about a year ago. The majority of TENORM waste rejected at PA and
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
,,
SHALE MOUNTAIN
R E S 0 U R C E S
Spam
Phish/Fraud
Not spam
GP026
To:
Subject:

'Kevin Koska'
RE: Conversation
Kevin,
Thank you so much for continuing to keep in touch with me on TERNORM.
You are correct on KRS 211.863. KRS is the Kentucky Revised Statues. The KAR (Kentucky Administrative Regulations)
which people follow closely, to my knowledge does not address what is required by KRS.
I have been concerned that Green Valley may be targeted to receive TENORM and want to investigate the situation,
checking their records on waste received.
To help me focus on where I need to be investigating, please help me with the following questions:
t/l.r
Who is telling the generators that this is a legal disposal option by the landfill facility?
Please provide any descriptions on how the waste would be contained, shipped or described.
Please provide a time period (days, months, etc.) that will help me narrow down the files I need to review to
identify waste received at Green Valley.
.
plans are to make an unannounced site visit once I know better who I need to meet with and where I need to focus
my time on regarding the review of files/manifest for waste being received by the facility. I will also be researching our
files here in Frankfort.
The Green Valley Facility owned by Republic Services from my understanding. I know the engineers and consultants that
work for that facility, both with Republic as well as the contractors/consultants.
With your help I will be able to document a situation which will help me to continue to build a case to expedite the
needed regulatory framework for Kentucky.
For this year I have been officially assigned to work on the TENO RM waste disposal issue for the Solid Waste Branch and
support the work that the Division of Waste Management in KOEP is doing to address it.
I look forward to hearing from you!
Thanks again for all you are doing,

Sincerely,
George
~Be P. PartrU:fge Jr., Pfi1J, P:E., !;2,'EP

artment for Environmental Protection

Frankfort, KY 40601
1
GP027
(502) 564-6716 ext. 4651
From: Kevin Koska [mailto:kevink@shalemtr.com]

--~-Sent:-Wednesday.,.January2Zr2016_U:Q3_Af\IL____"------- ----------~--------------------_._.~-----~--"-.----. --~To: Partridge, George (EEC)
Cc: David Patrick
George,
I am writing to inform you that the amount of high concentration TENORM waste being imported into Ky. for disposal is
of their TENO RM waste (that is too highly concentrated to enter or that has been rejected by Ohio, PA, and/or WV)
Respectfully,
Kevin
Kevin Kosko
Vice President
Shafe Mountain Resources
Phone: (937) 470-2655
SHALE MOUNTAIN
R E S 0 U R C E S
GP028

...-..9Kevin Koska <kevink@shalemtr.com>
pbject: RE: Conversation
Kevin;
Since we received two phone calls this week regarding TENORM, the Director of the Division of Waste Management has
, s e do not hesitate to call or email me anytime.

George

Cc: David Patrick
George,
g to local landfills.
GP029
This seems to be a similar situation that WV. was in about a year ago. The majority ofTENORM waste rejected at PA and
Ohio landfills was going to WV., when the press found out what was happening the backlash was so severe the gpvernor
'

Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
$HALE MOUNTAIN
R E S 0 U R 0 E S
Spam
Phish/Fraud
Not spam
GP030
-m:
Sent:
To:
Subject:

'Kevin Koska'
RE: Conversation
Kevin;
Since my previous email, I have been researching our files.
My understanding is that Norwich, Ohio is in Muskingum County. I have checked our records on Green Valley and they
are permitted to receive waste (not TENORM) from that County. Their records show they have only received "industrial
waste" from that county along with reporting the quantities they have received.
My next step is to inspect the manifest for the waste received by the landfill which they are required to keep for the past
three years.
If you have a list of companies or firms that could potentially be shipping wastes that contains TENO RM from that
county, that will be helpful. I do not know at this point if the manifests will show the type of wastes in detail or just
identify the company or source. Any assistance you can provide to help us confirm they are receiving TE NORM will be
helpful.
~e I receive your responses from my two email messages, the next step for me will be to visit the facility and inspect
~ir records.
Thanks again for all you are doing and supporting us addressing this concern regarding TENORM.
George
<;jeoree P. Partridjje Jr., Pli'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
From: Kevin Kesko [mailto:kevink@shalemtr.com]
Sent: Wednesday, January 27, 2016 11:03 AM

David Patrick
RE: Conversation
..
~ect:
George,
1
GP031
I am writing to inform you that the amount of high concentration TENO RM waste being imported into Ky. for disposal is
of their TE NORM waste (that is too highly concentrated to enter or that has been rejected by Ohio, PA, and/or WV)
to Advanced Waste's Green Valley Facility located in Ashland, Ky. Based on the regulation you sent (KRS 211.863) this i
.--Respectfulby1,
_.
Kevin
Kevin Kosko
Vice President
Phone: {937) 470-2655
SHALE MOUNTAIN
R E S b U R b E S

To: Kevin Kosko <kevink@shalemtr;com>
Kevin;
names, specifics, but only indicated in general terms that if we ignore takinga position on TENO RM, we will be
..
a..

2
GP032
....jl>olicy framework while being sensitive to all parties involved, including landfill management or companies that may
9-::.recognize or understand what they are facing as well as those like yourself that share important information we
George
From: Kevin Kesko [mailto:kevink@shalemtr.com]

Cc: David Patrick
George,
taking their waste from several brine recycling facilities in Ohio and PA. He stated that they were planning to take the 8~boxes {15 tons/box) that they produce daily to KY for disposal. I told him of our discussion and KRS 211.863 and he
~ s completely unaware of the statute. The waste from those facilities and others similar (that currently take waste to
This seems to be a similar situation that WV. was in about a year ago. The majority of TENORM waste rejected at PA and
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
..
GP033
SHALE MOUNTAIN
R E S 0 U R b E S
Spam
Phish/Fraud
Not spam
GP034
To:
Cc:
Subject:

David Patrick
RE: Conversation
George,
The three companies in or around Norwich that stated they ship waste to Kentucky are Environmental Energy Solutions,
Cambrian well services, and Pressure Tech. I guess my question would be if these companies can dispose of "industrial
waste" in Ohio why would they pay to ship it for disposal in KY?
The biggest shipment I kno.w of to date of high concentration TENO RM was from Fairmont Brine located in Fairmont
WV. The shipment (32 boxes) happened in late July or August of 2015 and if I recall the concentration was about 600
pCi/g. The WV Bureau of Radiation Protection got involved due to the high concentration in an attempt to make sure the
waste disposed of in a lawful manner. Jason Frame the Director contacted someone in the KYDEP and was told KY was a
legal disposal option and therefore released the Fairmont waste. If you would like to contact him directly his number is
304-356-4303. I will continue to keep my ears open and periodically touch base with you regarding this important issue.
Best Regards,

Kevin;
are permitted to receive waste (not TENORM) from that County. Their records show they have only received "industrial
three years.
If you have a list of companies or firms that could potentially be shipping wastes that contains TENO RM from that
identify the company or source. Any assistance you can provide to help us confirm they are receiving TENORM will be
helpful.
9e
I receive your responses from my two email messages, the next step for me will be to visit the facility and inspect
heir records.
Thanks again for all you are doing and supporting us addressing this concern regarding TENORM.
1
GP035
George
<georne P. Partritfae Jr., Pfi:D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Cc: David Patrick
George,
I am writing to inform you that the amount of high concentration TENO RM waste being imported into Ky. for disposal i s '
to Advanced Waste's Gree.n Valley Facility located in Ashland, Ky. Based on the regulation you sent (KRS 211.863) this is
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
GP036
R E S 0
U R C E S

Kevin;
. . . . . nk you for contacting our Solid Waste Branch. It was a pleasure to speak to you over the phone concerning a topic I
been concerned about and involved with for several years now.
rve
names, specifics, but only indicated in general terms that if we ignore taking a position on TENO RM, we will be
George
ef;;,Ke~in
Koska
[mailto:k~vink@shalemtr.com]
Sent: Wednesday, January 13, 2016 3: 12 PM

GP037
GP038
Subject:

Wednesday, January 27, 2016 ~:39 PM
'Kevin Koska'
RE: Conversation
Thank you for the helpful information. I will give Jason Frame a call tomorrow.
Thanks again so much for all you are doing. I will be actively looking into this in the days ahead.
I look forward to us keeping in touch!

Thank you,
George

Cc: David Patrick
.bject: RE: Conversation
George,
The three companies in or around Norwich that stated they ship waste to Kentucky are Environmental Energy Solutions,
Cambrian well services, and Pressure Tech. I guess my question would be if these companies can dispose of "industrial
waste" in Ohio why would they pay to ship it for disposal in KY?
The biggest shipment I know of to date of high concentration TENO RM was from Fairmont Brine located in Fairmont
WV. The shipment (32 boxes) happened in late July or August of 2015 and if I recall the concentration was about 600
pCi/g. The WV Bureau of Radiation Protection got involved due to the high concentration in an attempt to make sure the
waste disposed of in a lawful manner. Jason Frame the Director contacted someone in the KYDEP and was told KY was a
legal disposal option and therefore released the Fairmont waste. If you would like to contact him directly his number is
304-356-4303. I will continue to keep my ears open and periodically touch base with you regarding this important issue.
Best Regards,
Kevin

.vin;
1
GP039
are permitted to receive waste (not TENO RM) from that County. Their records show they have only received "industrial
..
A...
three years.
If you have a list of companies or firms that could potentially be shipping wastes that contains TENORM from that
identify the company or source. Any assistance you can provide to help us confirm they are receiving TENO RM will be
helpful.
Once I receive your responses from my two email messages, the next step for me will be to visit the facility and inspect
their records.
Thanks again for all you are doing and supporting us addressing this concern regarding TE NORM.
George
(ieorge P. Partridge Jr., Pfi'D, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Cc: David Patrick

George,
I am writing to inform you that the amount of high concentration TE NORM waste being imported into Ky. for disposal is
correct? Is the Advanced Waste Landfill facility truly a legal disposal option for highly concentrated TENORM generated '
GP040
Respectfully,
Kevin Kosko
Vice President
Phone: (937) 470-2655
R E
OU
E S


Kevin;
names, specifics, but only indicated in general terms that if we ignore taking a position on TENORM, we will be
Please continue to stay in touch as you le.am more.
olicy framework while being sensitive to all parties involved, including landfill management or companies that may
. .recognize or understand what they are facing as well as those like yourself that share important information we
GP041
..
George

._ .
Cc: David Patrick
~-Sent-:-WednesdayrJanuary-13, .201-6-3;1-2...RM
George,
Thank you for taking the time to talk with me today regarding TENORM disposal regulations in the state of Ky. You will
This seems to be a similar situation that WV. was in about a year ago. The majority of TE NORM waste rejected at PA a n .
Respectfully,
Kevin
Kevin Koska
Vice President
Phone: (937) 470-2655
R E S
0 U
E S

4
GP042
1~
~am
Phish/Fraud
Not spam
Spam
Phish!Fraud
Not spam
GP043
Subject:
Frame, Jason R <Jason.R.Frame@wv.gov>

Thursday, January 28, 2016 11:09 AM
FW: TNORM disposal in KY
Jason R. Frame B.S. R. T. (R), Chief Radiological Health Program

Office of Environmental Health Services/Radiation, Toxics and Indoor Air Division
350 Capitol Street, Room 313
Charleston, West Virginia 25301
Office: (304)356-4303
Fax: (304) 558-0524
Email: Jason.R.Frarne@WV.gov
From: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]
Sent: Tuesday, January 19, 2016 4:33 PM

To: Frame, Jason R
Cc: McKinley, Matthew W (CHS-PH); Brock, Stephanie C (CHS-PH)
Subject: RE: TNORM disposal in KY
Hello Mr. Frame,
Thank you for the follow-up e-mail on the purported disposition of WV TENO RM wastes here in KY by Advanced
TENORM Services of Liberty, KY (http://advtenorm.com/ ). We will follow up with the company's president, Cory
Hoskins, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
and Environment Cabinet Division of Waste Management since they regulate landfills here in KY.
Thanks again for reaching out to me regarding this matter.
Curt Pendergrass PhD
Supervisor, Radioactive Materials Section
~ucky Radiation Health Branch
~East Main Street
Mailstop HS1C~A
Frankfort, KY 40621
1
GP044
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
&..
~
Vnnfui!Jir~
IW..~-:..r....,JJ
ftiii.ttltfflONcAH~lliH
I -
----
- -
---
-~----~-~ ..- _ - --~--...=----------~--~-- - - - -
---------=--------------o------~-------------~~--~--~-----=---~~----""-------~-------------
From: Frame, Jason R [mailto:Jason.R.Frame@wv.gov]

To: Pendergrass, Curt (CHFS DPH)
Cc: Webb, April (EEC); George.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Mr. Pendergrass,
I apologize for digging up this old email, but I don't believe I received any further response. I believe a company
operating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please
advise on this issue. Thanks

Office: (304)356-4303
Fax: (304) 558-0524
Email: Jason.R.Frame@WV.gov
Sent: Tuesday, July 21, 2015 9:45 PM

To: Frame, Jason R
Hello Mr. Frame,
While KY does not currently have any regulations dealing with the control and disposal of NORM/TENORM waste
generated in the oil and gas industry from hydraulic fracturing, we do have statutes on the books establishing the Central
2
GP045
Midwest Interstate Low Level Radioactive Waste Compact of which KY is a member with IL. The compact strictly forbids
the disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously
udes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this el since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
ulatory purview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM/TENORM
contaminated waste so Advanced TENORM Services might want to check with the authorities in those states to see what
is required.
Regards,
Curt Pendergrass, Ph.D.
Radiation Health Branch
275 East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
This e-mail and any files are protected by the Electronic Communications Privacy
Act, 18 U.S.C. Sections 2510-2521. Its intended to be delivered only to the named
addressee(s) and its content is confidential and privileged. If you are not the
intended recipient or the person responsible for delivering the e-mail to the
intended recipient, be advised that you have received this e-mail in error and
that any use, dissemination, forwarding, printing, or copying of this e-mail is
prohibited. If you have received this e-mail in error, please notify the sender
by replying to this message and delete this e-mail immediately. Nothing in this
communication, either written or implied, constitutes or should be construed as a
...Aa1.1y binding agreement between the parties with respect to the subject matter
Frein.
From: Keffer, Christopher (CHFS Rad Hlth)

Cc: jason.r.frame@wv.gov
Subject: TNORM disposal in KY
Dr. Pendergrass,
I was contacted this morning by Mr. Jason R. Frame; a member of the West Virginia radiation program. He was
inquiring about a West Virginia company's intent to dispose of TNORM from a "fracking" operation here in Kentucky by
using the services provided by Advanced TENORM Services L.L.C. (
https://app.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
999 ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. (located in West Liberty, KY) will be solidifying
the "facking" sludge in Ashland, KY and then sending it to a Class D landfill in Irvine, KY. Mr. Fame's question was in
regards to whether or not we would allow the disposal of TMORN from other states in the state of Kentucky or send it
back to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNORM
in place and that each landfill may have their own limits on what they except or turn away in regards to radiation levels.
If you have any input on this matter please contact Mr. Frame at the e-mail address provided
(jason.r.frame@wv.gov ).
ristopher J. Keffer
iation Health Specialist Ill
ioactive Materials Section
275 East Main Street, HS1 C-A
Frankfort, KY 40601
Ph: 502-564-3700 x4179
3
GP046
Cell: 502 330-7662

FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may '
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
review, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
sender by reply e-mail and destroy all copies of the original message.
GP047

m:
I
Sent:
To:
Cc:
Subject:

Thursday, January 28, 2016 11:40 AM
'Frame, Jason R'
RE: TNORM disposal in KY
Jason;
Thank you for being so generous with your time and providing the helpful information as I seek to understand better the
TENORM issues affecting Kentucky.,
I looked at the email that you copied me on and my name is misspelled. The first "R" is left out of my name and I never
saw this.
I am so glad you have my correct email address.
I look forward to us keeping in touch.
Thank you,
George
f!//leorge P. PartrUfne Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Sent: Thursday, January 28, 2016 11:09 AM
Subject: FW: TNORM disposal in KY
. s o n R. Frame B.S. R.T. (R), Chief Radiological Health Program

1
GP048
Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,
Thank you for the follow-up e-mail on the purported disposition of WV TE NORM wastes here in KY by Advanced

Kentucky Radiation Health Branch
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of un~anted sources http://www.crcpd.org/StateServices/SCATR.aspx
V.outu
.)
l~~~IW;A(.M.. ~
f'A!I\ATl01'lMittilrn


2
GP049
elm:
Subject:

Thursday, January 28, 2016 12:21 PM
FW: TENORM disposal in KY
Tracking:
Recipient
Delivery
Delivered: 1/28/2016 12:21 PM
Sent:
To:
Lindsey;
I was referred to Jason Frame by Kevin Koska, Vice President of Compliance/Regulatory Affairs for Shale Mountain
Resources.
Kevin has shared with us that three facilities in Norwich, Ohio; Environmental Energy Solutions, Cambrian Well Services,
and Pressure Tech are taking all their TENO RM waste (that is too highly concentrated to enter or that has been rejected
by Ohio, PA, and/or WV) to Advanced Waste's Green Valley Facility located in Ashland, KY.
Kevin also informed me that a shipment of 32 boxes (tracker trailer trucks according to Jason) having radioactivity levels
in excess of 600 pCi/g were disposed of in Kentucky. The waste was received in Kentucky by Advanced TENO RM Services
located in West liberty, KY. Advanced TE NORM Services solidifies the "tracking waste" which is highly concentrated
_JjjRM (TE NORM) and then disposes of it at Blue Ridge Landfill in Irvine, KY. There are plans to continue shipment of this
r s t e to Kentucky.
Jason said the waste should have been sent out west to a facility that handles radioactive waste .
Jason corresponded with his counterpart in Kentucky, Dr. Curt Pendergrass with DPH. He also copied April Webb and
Maridely Loyselle and attempted to include me as well, but my name was misspelled and the email messages never
reached me.
My understanding is this waste disposal activity is prohibited by KRS 211.862/KRS 211.863.
Jason told me the waste is often just labeled as "tank bottoms" or 11 sludge".
I feel it is very important that someone investigate the company 11 Advanced TENORM Services" located here in Kentucky
as well as the landfills that have been brought to our attention that are accepting TENORM.
I feel we are endangering the well-being of landfill operators who handle this radioactive waste who my unknowingly
just think of it as an industry waste stream that is non-hazardous.
As I get phone calls and emails regarding TE NORM, I will forward them to your attention.
Thank you,
,
.rge
F~~m:"
Frame, Jason R [mailto:Jason.R.Frame@wv.gov]

1
GP050

Jason R. Frame B.S. R.T. (R), Chief Radiological Health Program

--~~ffic_e_;_(3Q4~5=~~4=30~3~~~
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
TENO RM Services of Liberty, KY (http:ljadvtenorm.com/ ). We will follow up with the company's president, Cory
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
!::-mail: curt.pendergrass@ky.gov
2
GP051

Mr. Pendergrass,
operating as "Advanced TENORM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
~des fracking wastes generated in West Virginia. I am Cc'ing my. colleagues in the Division of Solid Waste on this e~'1' since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
regulatory purview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM/TENORM
is required.
3
GP052
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
-.__ Eax:_5.02=5_6.4.::L492_._
. _. .__. -----------------------~-----------._.. _______ .
legally binding agreement between the parties with respect to the subject matter
herein.

Cc: jason. r .frame@wv.gov
Dr. Pendergrass,
inquiring about a West Virginia company's intent to dispose of TNORM from a "tracking" operation here in Kentucky by
the "tacking" sludge in Ashland, KY and then sending it to a Class D landfill in Irvine, KY. Mr. Fame's question was in
Christopher J. Keffer
Radiation Health Specialist Ill
Radioactive Materials Section
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
A..
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any . . .
GP053
-m:
Sent:
To:
Subject:
Maze, Rodney (EEC)

Partridge; George (EEC)
RE: TENORM disposal in KY
Never a dull moment! Thanks for the assistance.

Rodney
Sent: Thursday, January 28, 2016 4:55 PM

To: Maze, Rodney (EEC)
Subject: RE: TENORM disposal in KY
Rodney;
I look forward to us working together on this! Records we have in TEMPO indicate that industrial waste was received
from the Norwich, Ohio area by Green Valley. Also "Advanced TENORM Services" has been taking TENORM waste from
WV and disposing of it in KY according to government contacts in WV.
Would it be helpful to review manifests from last year to see what waste was received from out of state by the landfills
and the company sending it, since we know the names of companies supposedly sending the waste to Kentucky and the
, - e of waste we are looking for?

I will be available whenever I can be of assistance and look forward so much working with someone with your
experience and expertise.
Green Valley and Blue Ridge have been brought to our attention and it would not hurt to check out Big Run as welll since
it is a potential candidate for this type of waste.
Look forward to us staying in touch and scheduling our visits.
Thanks again for all you do for our Division!
George
From: Maze, Rodney (EEC)

Subject: FW: TENORM disposal in KY
George,
Looks like were on to a new adventure. I'll get with you next week and come up with a time and date to visit Green
Valley Landfill and Big Run Landfill to further the investigation of the alleged disposal of the radioactive waste. We might
~to investigate all my facilities before this over. Blue Ridge and Morehead is owned by the same company Advanced
9"-'Posal Services and has the same landfill manager (Billy Bowles).
GP054
This looks to be right up your alley and I have looked over the document you worked on concerning NORM and
TENORM. I'll need some help on this one, it's all new ground for me. I believe ERT has a NORM detector or if needed do
a multi-media inspection with the Rad Branch. I've worked with Mr. Pendergrass in the past.
A..
Thanks,
-~-29~.~1. - ..
From: Briggs, Lindsey (EEC)

Cc: Maybriar, Jon (EEC)
-~S=u=bject: _ f\/f; TENORM_ disp_Q__;;illn KY----~---------~~~--~ 0--~_,
_____________________________
-~----~~------------="-=----=--~-
FYI
Lindsey Briggs, PE
Environmental Engineer Supervisor
502 564 6716

To: Briggs, Lindsey (EEC)
Lindsey;
Resources.
and Pressure Tech are taking all their TENORM waste (that is too highly concentrated to enter or that has been rejected
by Ohio, PA, a_nd/or WV) to Advanced Waste's Green Valley Facility located in Ashland, KY.
in excess of 600 pCi/g were disposed of in Kentucky. The waste was received in Kentucky by Advanced TENO RM Services
located in West Liberty, KY. Advanced TENO RM Services solidifies the "fracking waste" which is highly concentrated
NORM (TE NORM) and then disposes of it at Blue Ridge Landfill in Irvine, KY. There are plans to continue shipment of this
waste to Kentucky.
reached me.
Jason told me the waste is often just labeled as "tank bottoms" or "sludge".
I feel it is very important that someone investigate the company "Advanced TENORM Services" located here in Kentucky
as well as the landfills that have been brought to our attention that are accepting TENO RM.
2
GP055
think of it as an industry waste stream that is non-hazardous.
Thank you,
George


Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
, , , Environment Cabinet Division of Waste Management since they regulate landfills here in KY.
GP056

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
~~--Website:ilttp:t/~_ww.cbfs.ky_.g_Q\lldpbha_dio_a_ctive,btm
_________________ -~ ________________________ ----~Pay your fees on line at https://prd.chfs.ky.gov/rad epay/

Kr!J!YitiiJ~
f'J\DlPirltfl'!~J-leJ~tH

Mr. Pendergrass,
I apologize for digging up this old email, but I don;t believe I received any further response. I believe a company

Office: (304)356-4303
Fax: (304) 558-0524
GP057
fll'10
Mr. Frame,
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
_.Ajressee(s) and its content is confidential and privileged. If you are not the
pended recipient or the person responsible for delivering the e-mail to the
herein.

Dr. Pendergrass,
using the services provided by Advanced TENO RM Services L.L.C. (
https://app.sos.kv.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
~ards to whether or not we would allow the disposal ofTMORN from other states in the state of Kentucky or send it
~k to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNORM
5
GP058
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
~~~contain-confidentiaHnformation-exempHroln'diselosure-uncter--applieable-la~lf-tl'lfroreaeef-0f-this-messa@e-is-not-the-intended-recipient,--you-are--notified-tl1at-anY--------~~-~
review, use, disclosure, distribution or copying of this com,munication is strictly prohibited. If you have received this communication in error, please contact the
sender by reply e-mail and destroy a\\ copies of the original message.
GP059
-m:
Sent:
To:
Cc:
Subject:

Friday, January 29, 2016 3:48 PM
'Frame, Jason R'
Jason;
I will be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding
TENORM disposal.
If you could provide additional information related to our conversation about the shipments by Advanced TENORM
Services to Kentucky that would be helpful.
As much detail as possible will be helpful as we review manifests, etc. at the landfills.
Information such as:
Number and type of trucks/ volume, etc. of the wastes .

Dates and time period the shipments were sent .
The form or appearance of the waste when it was shipped (before solidification). What does it look like?
Level of radioactivity.
Name of company in Fairmont along with County that contracted with Advanced TENO RM Services.
Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent to the landfill.
I know some of the above items we discussed in our conversation but I was so floored with the news I want to be sure I
confirmed the understanding we have of the situation before we move forward with site visits.
Also our Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
I appreciate all you and Curt do for our respective states.
Thanks again for all the time you devoted to corresponding and following up with us.
Look forward to hearing from you!
George
George P. Partridge Jr., Pfi'D, P.'E., Q_'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
..
GP060

~--"J'o~PaFtriElge1 Geerge-(66G}-.--------~~-~------~- --~----
- --.~-~--~. ---~.~.~--

Office: (W4)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,

2
GP061
Cc:
Subject:

David Patrick
RE: Conversation
George,
I understand you spoke to Jason Frame; thank you for following up. Jason is a really good guy who always seems to want
to "do the right thing". I think WV was in relatively the same situation about a year ago as Kentucky is in now. I worked
with him and Ken Holiday from WVDEP and as hard as they are trying, I think they are finding it tough sledding when it
comes to getting new rulemaking through the state legislature. Hopefully, Jason's experiences with this issue might help
you folks out.
I will continue to keep my eyes open for other instances where out of state TENORM being disposed of in Ky.
Best Regards,
Kevin
Kevin Kosko
. . I l e President
W:Ompliance/Regulatory Affairs
Phone: {937) 470-2655
SHALE MOUNTAIN
R E S 0 ~ A C E S

Kevin,
~nk
you so much for continuing to keep in touch with me on TERNORM.
Cu
are correct on KRS 211.863. KRS is the Kentucky Revised Statues. The KAR (Kentucky Administrative Regulations)
which people follow closely, to my knowledge does not address what is required by KRS.
GP062
I have been concerned that Green Valley may be targeted to receive TENO RM and want to investigate the situation,
checking their records on waste received.
To help me focus on where I need to be investigating, please help me with the following questions:
Who is telling the generators that this is a legal disposal option by the landfill facility?
Please provide any descriptions on how the waste would be contained, shipped or described.
Please provide a time period (days, months, etc.) that will help me narrow down the files I need to review to
identify waste received at Green Valley.
My plans are to make an unannounced site visit once I know better who I need to meet with and where I need to focus
my time on regarding the review of files/manifest for waste being received by the facility. I will also be researching our
files here in Frankfort.
The Green Valley Facility owned by Republic Services from my understanding. I know the engineers and consultants that
work for that facility, both with Republic as well as the contractors/consultants.
With your help I will be able to document a situation which will help me to continue to build a case to expedite the
needed regulatory framework for Kentucky.
For this year I have been officially assigned to work on the TENO RM waste disposal issue for the Solid Waste Branch and
support the work that the Division of Waste Management in KOEP is doing to address it.
I look forward to hearing from you!
Thanks again for all you are doing,

Sincerely,
George
(jeorge 'P. 'PartridiJe Jr., 'PfiV, 'P.'E., fl.'E'P

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Cc: David Patrick
George,
GP063
I am writing to inform you that the amount of high concentration TENORM waste being imported into Ky. for disposal is
...11/Jjheir TENO RM waste (that is too highly concentrated to enter or that has been rejected by Ohio, PA, and/or WV)
~Advanced Waste's Green Valley Facility located in Ashland, Ky. Based on the regulation you sent (KRS 211.863) this is
correct? Is the Advanced Waste Landfill facility truly a legal disposal option for highly concentrated TENO RM generated
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
SHALE MOUNTAIN
. . . ES 0 UR CE S
9""otect the future, recycle the past...

Kevin;
Since we received two phone calls this week regarding TE NORM, the Director of the Division of Waste Management has
w we need to respond here in Kentucky. This effort was initiated as a result of your phone call. I did not share
es, specifics, but only indicated in general terms that if we ignore taking a position on TENO RM, we will be
essing its disposal in landfills designated for other types of waste.
3
GP064
.,.,
a..
George

Cc: David Patrick
George,
Thank you for taking the time to talk with me today regarding TENORM disposal regulations in the state of Ky. You will
This seems to be a similar situation that WV. was in about a year ago. The majority of TENO RM waste rejected at PA and
Respectfully,
Kevin
Kevin Kosko
Vice President
Phone: (937) 470-2655
GP065
I
,
-4!.ALI;
MOU1'4TAlN
RESOUHGES
Spam
Phish/Fraud
Not spam
.Spam
Phi sh/Fraud
Not spam
GP066
-m
'l:it:
To:
Subject:
Maze, Rodney (EEC)

George,
have to investigate all my facilities before this over. Blue Ridge and Morehead is owned by the same company Advanced
Disposal Services and has the same landfill manager (Billy Bowles).
TENO RM. I'll need some help on this one, it's all new ground for me. I believe ERT has a NORM detector or if needed do
Thanks,
B._~~.Y ~"''""~"" -"""" ",,., ""'""""""""" "'"'"""""""""


Lindsey Briggs, PE
502 564 6716

Lindsey;
Resources.
and Pressure Tech are taking all their TENORM waste (that is too highly concentrated to enter or that has been rejected
l v i n also informed me that a shipment of 32 boxes (tracker trailer trucks according to Jason) having radioactivity levels
in excess of 600 pCi/g were disposed of in Kentucky. The waste was received in Kentucky by Advanced TENORM Services
located in West Liberty, KY. Advanced TENO RM Services solidifies the "tracking waste" which is highly concentrated
1
GP067
waste to Kentucky.
Jason said the waste should have been sent out west to a facility that handles radioactive waste.
reached me.
'
as well as the landfills that have been brought to our attention that are accepting TE NORM.
As I get phone calls and emails regarding TENORM, I will forward them to your attention.
Thank you,
George


Office of Environmental Health Services/Radiation, To~dcs and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524
GP068

Frame, Jason R
McKinley, Matthew W (CHS-PH); Brock, Stephanie C (CHS-PH)
bject: RE: TNORM disposal in KY
I.
Hello Mr. Frame,

Thank you for the follow-up e-mail on the purported disposition of WV TENORM wastes here in KY by Advanced
TENO RM Services of Liberty, KY (http://advtenorm.com/ ). We will follow up with the company's president, Cory
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Y your fees on line at https://prd.chfs.ky.gov/rad epay/
notified of proposed regulation changes https:f/secure.kentucky.gov/Regwatch/
spose of unwanted sources http://www.crcpd.org/StateServices/SCATR.aspx
-
/(tzJ//J)_M -
i'~ft,!Jl).\TJON/A,H~ALTH

Mr. Pendergrass,

Office: {304)356-4303
Ac: (304) 558-0524
. a i l : Jason.R.Frame@WV.gov
GP069
I

To: Frame, Jason R
Hello Mr. Frame,

is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
________..
-----.
4
GP070

bject: TNORM disposal in KY
Pendergrass,
' inquiring about a West Virginia company's intent to dispose of TNORM from a "fracking" operation here in Kentucky by
regards to whether or not we would allow the disposal of TM ORN from other states in the state of Kentucky or send it
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
tain confidential information exempt from di!)closu.re under applicable law. If the reader of this message is not the int.ended recipient, you are notified that any
iew, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
nder by reply e-mail and destroy all copies of the original message .
'
GP071
'elm,
To:
Sent:
Subject:
Microsoft Outlook
Delivered: FW: TENORM disposal in KY
Your message has been delivered to the following recipients:

Briggs, Lindsey (EEC) (Lindsey.Briggs@ky.gov)
GP072
9'om:
To:
Sent:
Subject:

Read: TENORM disposal in KY
Your message
Sent: Thursday, January 28, 2016 12:20:34 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Thursday, January 28, 2016 12:23:28 PM (UTC-05:00) Eastern Time (US & Canada).
GP073
fl.m:
Sent:
To:
Subject:
Maze, Rodney (EEC)

George,
TENORM. I'll need some help on this one, it's all new ground for me. I believe ERT has a NORM detector or if needed do
Thanks,

'bject: FW: lENORM disposal in KY
Lindsey Briggs, PE
502 564 6716

Lindsey;
Resources.
Ohio, PA, and/or WV) to Advanced Waste's Green Valley Facility located in Ashland, KY .
evin also informed me that a shipment of 32 boxes (tracker trailer trucks according to Jason) having radioactivity levels
in excess of 600 pCi/g were disposed of in Kentucky. The waste was received in Kentucky by Advanced TENORM Services
1
GP074
waste to Kentucky.
reached me.
..
as well as the landfills that have been brought to our attention that are accepting TE NORM.
Thank you,
George

'

Office: (304)356-4303
Fax: (304) 558c0524
GP075
Mr. Pendergrass,
~ologize for digging up this old email, but I don't believe I received any further response. I believe a company

Office: (304)356-4303
Fax: (304) 558-0524
"-----------------
---------' ------- ...

To: Frame, Jason R
Hello Mr. Frame,

is required.
Regards,
iation Health Branch
East Main Street
lstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
3
GP076
Fax: 502-564-1492
~communication,__eitber_wr:itterLoLJmplied,~cor:istitutes_or~sbould_be~cor:istrued.as-a----~ -----------~~-----~~------legally binding agreement between the parties with respect to the subject matter
herein.

Dr. Pendergrass,
https://app.sos.ky.gov/ftshow/(S(30ygolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
'
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP077
is required.
fl'1ards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
prohibited. If you have received this e-maii in error, please notify the sender
herein.
m: Keffer, Christopher (CHFS Rad Hlth)

t: Tuesday, July 21, 2015 1:19 PM
Dr. Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
~--= 502 330-7662

" " " ' : 502-564-1492
I
!
GP078
"m:
Sent:
To:
Subject:

Maze, Rodney (EEC)
RE: TENORM disposal in KY
Rodney;
I look forward to us working together on this! Records we have in TEMPO indicate that industrial waste was received
from the Norwich, Ohio area by Green Valley. Also "Advanced TENORM Services" has been taking TENORM waste from
WV and disposing of it in KY according to government contacts in WV.
Would it be helpful to review manifests from last year to see what waste was received from out of state by the landfills
and the company sending it, since we know the names of companies supposedly sending the waste to Kentucky and the
type of waste we are looking for?
I will be available whenever I can be of assistance and look forward so much working with someone with your
experience and expertise.
Green Valley and Blue Ridge have been brought to our attention and it would not hurt to check out Big Run as well! since
it is a potential candidate for this type of waste.
, k forward to us staying in touch and scheduling our visits.

Thanks again for all you do for our Division!
George

George,
Valley Landfill and Big Run Landfill to. further the investigation of the alleged disposal of the radioactive waste. We might
TE NORM. I'll need some help on this one, it's all new ground for me. I believe ERT has a NORM detector or if needed do
Thanks,
.~~~':l!:Y . . . .
m: Briggs, Lindsey (EEC)
t: Thursday, January 28,
I
i
2016 3:55 PM
Maze, Rodney (EEC)
1
GP079
FYI
Lindsey Briggs, PE
502 564 6716
From: Partridge;Geo-rge (EEC)____ _


Lindsey;
I was referred to Jason Frame by Kevin Kosko, Vice President of Compliance/Regulatory Affairs for Shale Mountain
Resources.
in excess of 600 pCi/g were disposed of in Kentucky. The waste was received in Kentucky by Advanced TEf{lORM Services
NORM (TENO RM) and then disposes of it at Blue Ridge Landfill in Irvine, KY. There are plans to continue shipment of t h i .
waste to Kentucky.
&.
reached me.
as well as the landfills that have been brought to our attention that are accepting TENO RM.
Thank you,
George
GP080

....a_Partridge, George (EEC)
r"ject: FW: TNORM disposal in KY

Office: (304)356-4303
Fax: (304) 558-0524
Email: Jason.H.Frame@WV.gov
From: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Penderqrass@ky.gov]

To: Frame, Jason R

Hello Mr. Frame,
TENORM Services of Liberty, KY (http:Uadvtenorm.com/ ). We will follow up with the company's president, Cory
Mailstop HS1C-A
Frankfort, KY 40621
502-564-3700 ext. 4183
502-564-1492
..
Website: http:ljwww.chfs.ky.gov/dph/radioactive.htm
3
GP081

Be notified of proposed regulation changes https:Usecure.kentucky.gov/Regwatch/
UaHfUCJt;~
l~!'IM-!Jt..Ywy
f~.AD'!ATJON1-1&\l.TH

cc: Webb, April (EEC); GeOrge.Patridge@l<Y-9oVTloyselle~Maridely---CEEC}; Reffer~Cl'frisropffer(CFIFS~RacrFlttn)~~~..~~---
Mr. Pendergrass,
operating as" Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KV landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Subject: RE: TNORM disposal in KV
Hello Mr. Frame,
While KV does not currently have any regulations dealing with the control and disposal of NORM/TENORM waste
the disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously . .
a._
GP082

_ljbject: TNORM disposal in KY
-
Pendergrass,
https:Uapp.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
999 ). From Mr. Frames understanding, Advanced TENORM Services L.l.C. (located in West Liberty, KY) will be solidifying
back to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TN ORM
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
tain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
ew, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
derby reply e-mail and destroy all copies of the original message .
-
..
5
GP083

Mailstop HS1C-A
nkfort, KY 40621
: 502-564-3700 ext. 4183
Fax:502-564-1492
Be notified of proposed regulation changes https:ljsecure.kentucky.gov/Regwatch/
It!!!~
1lttH~ttli,t.TH
11'.AOJJ\


Mr. Pendergrass,
~son R. Frame B.S. R.T. (R), Chief Radiological Health Program

.-tfice of Environmental Health Services/Radiation, Toxics and Indoor Air Division
Office: {304)356-4303
Fax: (304} 558-0524

Frame, Jason R
Webb, April (EEC); George.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
GP084
Hello Mr. Frame,

'
~-----is_r_equired. ___~-__ ---------~------- _____ ---~---__ ~- ----~----------~-----------___---~~~----------~----------- -~-~~--~-Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
prohibited. If you have received this e~mail in error, please notify the sender
herein.

Dr. Pendergrass,
I was contacted this morning by Mr. Jason R. Frame; a member ofthe West Virginia radiation program. He was
using the services provided by Advanced TE NORM Services L.L.C. (
https://app.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hgoreemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
,~o<
999 ). From Mr. Frames understanding, Advanced TEN'DRM Services L.L.C. (located in West Liberty, KY) will be solidifying
back to the materials origins. I informed Mr. Frame that our office does not currently have-regulation regarding TNORM
~
L_
4
GP085

ankfort, KY 40601
: 502-564-3700 x4179
II: 502 330-7662
FAX: 502-564-1492
sender by reply e-mail and destroy all copies of the original message .
GP086
f'5:.~:
To:
Subject:
Attachments:
Tracking:

Maze, Rodney (EEC)
RE: TENORM and Advanced TENORM Services
Advanced TENO RM Services Company Information - 012916.pdf; TENORM Notes for
Rodney - 012916.docx
Recipient
Delivery
Maze, Rodney (EEC)
Delivered: 1/29/2016 4:17 PM
Rodney;
Please find attached some general notes I put together on TENO RM along with the company information I obtained
from the Web Site for "Advanced TENORM Services" and our records in TEMPO.
I saw no activity in TEMPO under Solid Waste, Hazardous Waste, or Air; only Wastewater.
I also am following up with Jason Frame with WV.gov to see if he can provide any more details regarding shipment of
waste from Fairmont that Advanced TENO RM Services handled.
I am still trying to grasp how all this activity on TENO RM disposal is taking place (according to out of state contacts) and
are not seeing any TEMPO activity regarding permitting, etc ..
I look forward to learning more about TENO RM with you and pursuing this investigation.
Hope the week went well for you.
Have a nice weekend,
George
<jeorge P. PartrUfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
..
1
GP087
#m:
Sent:
To:
Subject:

Monday, February 01, 2016 7:34 AM
Maze, Rodney (EEC)
RE: Site Visits
Tracking:
Recipient
Delivery
Read
Maze, Rodney (EEC)
Delivered: 2/1/2016 7:34 AM
Read: 2/1/2016 7:53 AM
Rodney;
When we visit the sites to investigate for disposal of TENORM, I would like if possible to check all the solidification pits at
the sites we visit for the presence of TE NORM waste. We may find waste coming into Kentucky from other sources we
are not aware of.
As I recall you have available or will be able to bring a detector with you that is suitable for that purpose.
This is something I am not familiar with (radiation detectors). Please let me know if I need to research or follow up with
anyone here in Frankfort, etc. regarding getting any equipment we need.
I will print out the quarterly records on the sites we visit that show the quantities and the counties/states waste has
_t/j;jen received.
Sanks again for calling last Friday.
Look forward to staying in touch as the week progresses.
Thank you!
George
(ieorge P. Partrid{Je Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP088
#m
:.t;
To:
Subject:
Attachments:
Maze, Rodney (EEC)

Re: Site Visits
imageOOl.gif
George
Let me check on the norm meter and I'll get back with you
Rodney Maze
On Feb 1, 2016, at 7:33 AM, Partridge, George (EEC) <George.Partridge@ky.gov> wrote:

Rodney;
When we visit the sites to investigate for disposal of TENO RM, I would like if possible to check all the
solidification pits at the sites we visit for the presence of TENO RM waste. We may find waste coming
into Kentucky from other sources we are not aware of.
As I recall you have available or will be able to bring a detector with you that is suitable for that purpose.
This is something I am not familiar with (radiation detectors). Please let me know if I need to research
or follow up with anyone here in Frankfort, etc. regarding getting any equipment we need.
I will print out the quarterly records on the sites we visit that show the quantities and the
counties/states waste has been received.
Thanks again for calling last Friday.
Look forward to staying in touch as the week progresses.
Thank you!
George
(jeorge P. PartridfJe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
..
<image001.gif>
GP089
-m:
Sent:
To:
Subject:

Higginbotham, Jeri (EEC)
RE: Questions Regarding Radiation Risk
Jeri;
I am looking at radiation risk exposure numbers and some tracking wastes and have some questions I thought you might
could help me with.
Please let me know a co.nvenient time I could stop by and show you what I am looking at and get your insights.
Thank you and have a nice day!
George
(jeorge 'P. 'PartridiJe Jr.

Frankfort, KY 40601
f/102) 564-6716 ext. 4651
GP090
Partridge, George (EEC}
-m:
Sent:
To:
Cc:
Subject:
Attachments:

Fairmont Brine plan.pdf
Number and type of trucks/ volume, etc. of the wastes. 35 vac boxes, unsure of volume but tractor trailer size.
Dates and time period the shipments were sent. Shipments occurred during August 2015.
Varied but typically a brown sludge, with a water layer on top.
Level of radioactivity. Exposure rates were between 500 uR/hr and 2 mR/hr
Name of company in Fairmont along with County that contracted with Advanced TENO RM Services. Fairmont
Brine
Any knowledge where it was sent for solidification in Ashland, KY (?) prior to being sent to the landfill. See
attatchment

~rleston, West Virginia 25301
W'ffice: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
.-n;
Cc: Pendergrass, Curt (CHFS DPH)
I will be jofning our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding
TENORM disposal.
1
GP091
If you could provide additional information related to our conversation about the shipments by Advanced TENO RM
~~~~.
Number and type of trucks/ volume, etc. of the wastes.

Dates_and_time~periru:Ltne_shipm~nts_wexe_~ent_
.. _... _______. _.___. __________---------~~------~~~~~-~~--~-The form or appearance of the waste when it was shipped (before solidification). What does it look like?
Name of company in Fairmont along with County that contracted with Advanced TENORM Services.
I know some of the above items we discussed in our conversation but I was so floored with the news I wantto be sure I


George
(jeor9e P. PartridiJe Jr., Pfi'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


2
GP092

Office: (304)356-4303
~: {304) 558-0524
..-"ail: Jason.R.Frame@WV.gov

To: Frame, Jason R
Hello Mr. Frame,
~ank
you for the follow-up e-mail on the purported disposition of WV TE NORM wastes here. in KY by Advanced
"9.:NORM Services of Liberty, KY (http:Uadvtenorm.com/ ). We will follow up with the company's president, Cory
I
275 ~ast Main Street
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502c564-3700 ext. 4183
Fax:502-564-1492
Pay your fees on line at https:ljprd.chfs.ky.gov/rad epay/
Dispose of u~wanted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
/(t>/JJl!JNf
I
1
f'.AD1Atl0tt~.H;El.t.1tl
~;;;~F;:;;;;;;:;;;.;~Rr;;;.;n;;i;;.;~~11::;:;,,;;;;@;;:~~~isent: Tuesday, January 19, 2016 12:51 PM

3
GP093

Mr. Pendergrass,
~_J_a_s_on
R._Frame B.S. R. T. (R), Chief _R~diologicatH~~alth Program

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
is required.
Regards,
Mailstop HSlC-A
4
GP094
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
~: 502-564-1492
- s e-mail and any files are protected by the Electronic Communications Privacy
intended recipient, be advised that you ha.ve received this e-mail in error and
herein.
From: Keffer, Christopher (CHFS Ri;id Hlth)

Dr. Pendergrass,
inquiring about a West Virginia company's intent to dispose ofTNORM from a "fracking" operation here in Kentucky by
t s: a .sos.k : ov ftshow S 30 olkfdaebcz4h oreem 4 default.as x? ath=ftsearch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP095
-m:
Sent:
To:
Subject:
Attachments:

Monday, February 01, 2016 12:17 PM
Fairmont Brine plan.pdf; TENORM Notes for Rodney - 012916.docx
Jeri;
Latest information just received.
Thanks for your help!
George
Sent: Monday, February 01, 2016 11:30 AM

Number and type of trucks/ volume, etc. of the wastes. 35 vac boxes, unsure of volume but tractor trailer size .
Brine
Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent to the landfill. See
attatchment

Office of Environmental Health Services/Radiation, Toxrcs and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524
..
1
GP096
From: Partridge, George (EEC) [mailto:George.Partridge@ky.gov}

To: Frame, Jason R
Jason;
TENORM disposal.

Dates and time period the shipments were sent.
The form or appearance ofthe waste when it was shipped (before solidification). What does it look like?
Name of company in Fairmont along with County that contracted with Advanced TE NORM Services.
George
<jeorge P. PartrUfee Jr., Pfi'D, P.'E., Q'EP

2
GP097

Frankfort, KY 40601
. .2) 564-671.6 ext. 4651

Jason R. Frame B.S. R. T. (R}, Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
~kins, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
~ Environment Cabinet Division of Waste Management since they regulate landfills here in KY.
3
GP098

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
~~.~~.W_eb5Re:ll1tp_:/Lw_ww .chfs. kv,_govLdi;i h/rad ioactive. htm
HH
mHH
-------
-----
Pay your fees on line at https:Uprd.chfs.ky.gov/rad epay/

Dispose of unwanted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
V.n". ~.t/1.
'R
_n.2-
I~~

Mr. Pendergrass,

Office: {304)356-4303
Fax: (304) 558-0524
--
To: Frame, Jason R

4
GP099

. - o Mr. Frame,
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
~ressee(s) and its content is conf1.dential and privileged. If you are not the
pended recipient or the person responsible for delivering the e-mail to the
herein.

Dr. Pendergrass,
ards to whether or not we would allow the disposal of TMORN from other states in the state of Kentucky or send it
k to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNORM
5
GP100
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: .This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
-----eontaineonfidentiaHnfermation-exem13Hr0m-Elisel0sure-unEler-a1313licable-law~-lf-the-reader-of-tl:iis-message-is-noUhe-intended-recipient,~you.are..notified-thatany~~ review, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
GP101
-m:
Sent:
To:
Subject:
Attachments:

Fairmont Brine plan.pdf; TENORM Notes for Rodney - 012916.docx
Jeri;
George

Name of company in Fairmont along with County that contracted with Advanced TENORM Services. Fairmont
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
GP102

To: Frame, Jason R
Jason;
TENORM disposal.

Any knowledge where it was sent for solidification in Ashland, KY (7) prior to being sent to the landfill.
Look forward to hearing from you l
George
(jeorge P. PartridiJe Jr., Pfi'D, P.'E., fl.,'EP

2
GP103

Frankfort, KY 40601
, , , 2 ) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
. From: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]

To: Frame, Jason R
Hello Mr. Frame,
TENORM Services of liberty, KY (http://advtenorm.com/ ). We will follow up with the company's president, Cory
~skins, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
wrnd Environment Cabinet Division of Waste Management since they regulate landfills here in KY.
3
GP104
'

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~-~-~.ebsite:bttp_:LlW_ww.cbf5,kv.goY'Ldpb/[ad inactive. htm ..

"VnnfU~.
~t.-....~iwY.
;-uw1A1Tt.m_&Hattl.TH
Cc: Webb, April (EEC); Georqe.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
4
GP105
&
W
e9io
Mr. Frame,
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TE NORM in landfills here in KY is their
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
, 18 U.S.C. Sections 2510-2521. Its intended to be delivered only to the named
ressee(s) and its content is confidential and privileged. If you are not the
ended recipient or the person responsible for delivering the e-mail to the
herein.

Dr. Pendergrass,
https:/(app.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
.....erds to whether or not we would allow the disposal ofTMORN from other states in the state of Kentucky or send it
~~to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNORM
5
GP106
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
~-----eontaiF1-eoF1fidentiaHnfermatioAexemf)t-fmnrdiselosureuAEler-af)fllieable-laW;-~IHhe-reaEler-ofthis-message-is-not-the-intenEleEl-reeif)ientcYOU-are-nolifieEl-that-any~~--
GP107
Partridge, George {EEC)

. .m:
Sent:
To:
Subject:
Attachments:

Maze, Rodney (EEC)
Rodney;
Latest information I received from Jason from WV.
George

,,.
Dates and time period the shipments were sent. Shipments occurred during August 2015 .
Name of company in Fairmont along with County that contracted with Advanced TENORM Services ..Fairmont
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
GP108

To: Frame, Jason R
Jason;
____ !will be J?~~g o~~!!eld_~nsp_e_~~_i:_s ~l~n9!i!ls_a~_d__""~_st~-~-t~siri__~~s!~_r_~_~en~~ckyt~i-~ve_st~~~-~~?_l-1~5~-~c~~~s__re!\.~~~~~~-TENORM disposal.

Level of radioactivity .
Name of company in Fairmont along with County that contracted with Advanced TENO RM Services .
Any knowledge where it was _sent for solidification in Ashland, KY(?) prior to being sent to the landfill.
George
<jeorge P. Partricf8e Jr., PfiV, P/E., Q'.EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP109

ject: FW: TNORM disposal in KY
..

Office: (304)356-4303
Fax: {304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
and Environment Cabinet Divisioh of Waste Management since they regulate landfills here in KY.
Mailstop HSlC-A
Frankfort, KY 40621
...... 502-564-3700 ext. 4183
~: 502-564-1492
Website: http://www.chfs.ky.govI dph/rad ioactive. htm
3
GP110

Vanmfhr~
,~,&l~,,,~~Y
f'.AD'J.t\ilONJi:il:At TH

tc-: we55, Aprll(EEC:};~Ge6fc!e.Parriage@Kf.9ov;-To)'selle~-Marioely (EECJrKeffer,-chfistoplierTCFIFS~Raa~R1t11r-------~-subject: RE: TNORM disposal in KY

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
the disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously ~
includes tracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
A.
GP111
is required.
~ards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
m:
Keffer, Christopher (CHFS Rad Hlth)

Dr. Pendergrass,
inquiring about a West Virginia company's intent to dispose ofTNORM from a "tracking" operation here in Kentucky by
https:ljapp.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
. . . . . . . . .: 502 330-7662
.I ~: 502-564-1492
GP112
Cc:
Subject:
Attachments:

McKinley, Matthew W (CHS-PH)
Fairmont Brine plan.pdf; KRS 224.46-530_statute.pdf
Hello Matt,
Looks like we have TE NORM contaminated hydraulic fracturing waste generated in WV being disposed of here at a
subtitle D solid waste landfill in Irvine, KY. The exposure rates were between 0.5-2.0 mR/hr according to Jason Frame
with WV (see attached). The work was done by Advanced TENORM services in West Liberty, KY
(http://advtenorm.com/services/ ). Exactly where the waste was processed before disposal is a mystery. A quick Google
search turned up the following landfill in Irvine run by Advanced Disposal
(http://www.adva ncedd isposa I.com/ky/irvine/bl ue-ridge-la ndfi 11 ) :
Blue Ridge Landfill - Irvine, KY

2700 Winchester Road
Irvine, KY 40336
Scale House Phone: 606-723-5552
Fax: 606-723-5607
General Manager
Email: Charles.Laws@AdvancedDisposal.com
Special Waste Expert: Billy Bowles
Phone: 606-975-7053
Email: Billy.Bowles@AdvancedDisposal.com
This is an obvious violation of the Central Midwest Compact, our regulations and not to mention EEC regulations
governing waste disposal including KRS 224.46-530, (l)(k). I think that it is time that we sit down with Dr. George
Partridge and Danny Anderson in EEC and hash out this issue. Obviously, what we need is a set of complimentary
TENORM regs.
Let me know if you have time here in the next few weeks and I will arrange a meeting with EEC to discuss this issue.
Thanks,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
9site: http:ljwww.chfs.ky.gov/dph/radioactive.htm
. a y your fees on line at https://prd.chfs.ky.gov/rad epay/
1
GP113

f\turrfoer-andtyp-e-ohraclrstvc:Jlome;-etcoi-th-e-wastes~35-vacboxe~;-unsareotvolume~burtractartraiiersize:" ~~~"~-
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
I will be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regardiniA.
TENORM disposal.
~
GP114
-------
---- -------- ---------------
, e9rnuch detail as possible will be helpful as we review manifests, etc. at the landfills.

,rge
(ieorge P. Partricfge Jr., Pft'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

.._.9on R. Frame B.S. R.T. (R), Chief Radiological Health Program

~e of Environmental Health Services/Radiation, Toxics and Indoor Air Division

Office: (304)356-4303
3
GP115
Fax: {304) 558-0524


To: Frame, Jason R
Hello Mr. Frame,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
KrtJJHe?rl~
flJ.\ttlATIO'i~~Hl~At:n1

Cc: Webb, April (EEC); Georqe.Patridqe@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
4
GP116
.....
~
Mr. Pendergrass,
~ologize for digging up this old email, but I don't believe I received any further response. I be.lieve a company
~-~rating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524
~.--.-...........................- ........~.........
..........................................,.,.........................
,_
9fr~m: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]

To: Frame, Jason R
Hello Mr; Frame,
Midwest Interstate Low Level Radioactive Waste Compact of which KY is a member with IL The compact strictly forbids
is required.
Regards,

East Main Street
stop HS1C-A
rankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
GP117
~-----MLe~---.~-~~- _________ __ _
___ __ _ ____ -------~----------

Dr. Pendergrass,
in place and that each landfill may have their own limits on what they except or turn away in regards to radiation levels.~
&..
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable law. If the. reader of this message is not the intended recipient, you are notified that any
sender by reply e-mail arid destroy all copies of the original message.
GP118
To:
Cc:
Subject:

I am open Feb 23, 24, 26, Mar 1, 2, 3. I agree that specific TE NORM regulations would go a long toward preventing this
type of activity. In the meantime, they need to be made aware of the existing regulations (both RHB and EEC) that they
have apparently violated.
From: Pendergrass, Curt (CHFS DPH)
Sent: Monday, February 01, 2016 12:25 PM

To: McKinley, Matthew W (CHS-PH)
Cc: Partridge, George (EEC)

Hello Matt,
looks like we have TE NORM contaminated hydraulic fracturing waste generated in WV being disposed of here at a
with WV (see attached). The work was done by Advanced TENORM services in West liberty, KY
t : advtenorm.com services ). Exactly where the waste was processed before disposal is a mystery. A quick Google
rch turned up the following landfill in Irvine run by Advanced Disposal
(http://www.adva nceddisposa l.com/ky/i rvi ne/bl ue-ridge-la ndfil I ) :

~~
Irvine, KY 40336
Fax: 606-723-5607
General Manager
Emai I: Charles.Laws@AdvancedDisposal.com
Phone: 606-975-7053
TENORM regs.
let me know if you have time here in the next few weeks and I will arrange a meeting with EEC to discuss this issue.
Thanks,
....... Pendergrass PhD
~ervisor, Radioactive Materials Section

1
GP119
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
-~~--------c~-~------~---------~-----~----
..
--------- -
- - -----------------------

Brine
attatchment
Jason R. Frame B.S. R. T. (R), Chief Radiological Healtlt Program

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
2
GP120
&..
'W

e&n;
TENORM disposal.

~o our Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
~ppreciate all you and Curt do for our respective states.

George
<;]eorge P. PartridjJe Jr., PnV, P.'E., QTP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
.................. ~ .................... ..
: Frame, Jason R [mailto:Jason.R.Frame@wv.gov]

3
GP121

Office: (304)356-4303
Fax: (304) 558-0524
~~~---~l~mai l~-J ason.R.i;r-am e@W'-J_,ggv~~~--H
--

To: Frame, Jason R
Hello Mr. Frame,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
GP122
,~
Vanh VY'l.U,-.,.'
l~:f!!!l~~~
e'!.JAtitJN/AH!!A<TH
Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Cc: Webb, April (EEC); George.Patridge@ky;gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Hello Mr. Frame,

includes tracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this esince disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
latory purview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM/TENORM
is required.
5
GP123
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
_______Ea~c_5_Q2:56~-=--H_9_2_.--~-~~~------------ ----------------------------------------------------~~~~----------- ___ --------------~-~---------------~-~-~-~----~---~~-This e-mail and any files are protected by the Electronic Communications Privacy
by replying to this message and delete this ~-mail immediately. Nothing in this
herein.

Dr. Pendergrass,
Frankfort, KY 40601.
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may . . . .
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any~
GP124
'elm:
Sent:
To:
Subject:

Hi Curt;
We are actively investigating the notice we received from Jason Frame (WV) that TENO RM waste was disposed of here
in Kentucky. I am also investigating three other companies in Ohio that we were informed of regarding TENO RM waste
disposal in Kentucky.
I plan to be visiting landfills in eastern KY on Thursday of this week as well as visiting Advanced TENO RM Services located
in West Liberty.
Rodney Maze (field office) with our Division and I are working together on this.
It is unfortunate that I did not get the email messages that were sent to me last year or earlier this year in January since
my name was misspelled on the email address. Once I learned of the situation I have been actively pursuing it.
I am not familiar with monitoring for TE NORM. Are there detectors (portable, hand held, etc.) that could be made
available to Rodney and I when we conduct the site visits? We plan to inspect the waste solidification basins where the
,.Aste would be treated before landfilling as well as the area where the waste would have been disposed of at the
We also realize the landfills may be receiving in-state generated waste as well which is not regulated and has been
disposed of in landfills here before.
Fe.
Thanks for your help and inte;est as always,

George


Hello Matt,
(http:/ladvtenorm.com/services/ ). Exactly where the waste was processed before disposal is a mystery. A quick Google
(http://www.adva ncedd isposa I.com/ky/i rvine/bl ue-ridge-la ndfill ) :

Irvine, KY 40336
Fax: 606-723-5607
1
GP125
General Manager
Phone: 606-975-7053
TENORM regs.
--------=---=-----=-----------------
-~---'-=--'--'--"------o~---.o-.---- - -- - -
--=---~-------'--~--c-------~--1-~ _________ , _ _ -~-~..-=-:--------0-~------'".=...-~~~~-~'-~-~-
Thanks,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
_z,'.
_en__ -_-.-_._m_--~----_-R_
1,,.,f.~~~
.
t'tAOl;.\TIONJb.t-t:etU:.:rn

Name of company in Fairmont along with County that contracted with Advanced TE NORM Services. Fairmont
Brine
attatchment

2
GP126
Office: {304)356-4303
Fax: {304) 558-0524
. .ail: Jason.R.Frame@WV.gov
From:Partridge, George (EEC) [mailto:George.Partridge@ky.gov]
To: Frame, Jason R


Jason;
, O R M disposal.

The form or appearance of the waste when it was shipped {before solidification). What does it look like?
Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent to the la11dfill.
, k s again for all the time you devoted to corresponding and following up with us.
George
3
GP127
fgeorge P. PartridiJe Jr., Pli'D, P.'E., Q,'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,
TENO RM Services of liberty, KY (http://advtenorm.com/ ). We will follow up with the company's president, Cory
4
GP128
----
--------
fljanks again for reaching out to me regarding this matter.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of unwanted sources http:Uwww.crcpd.org/StateServices/SCATR.aspx
v'"t1ii!lr~t},,
l~~~~-:!l
f~ti1A"NO't~.H~AL'frl

,,,,.l/j: Webb, April (EEC); George.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
rbject: RE: TNORM disposal in KY
..
Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
GP129

To: Frame, Jason R
Hello Mr. Frame,
--~- -generatecnnth-e 011~ana~gas in11ustFrfrom-hytlraulic-fracturing;-we~dffhave~statutes~on-the-books-establishing-the-eentral--~-
includes fracking wastes generated in West Virginia. I am Cc'ing, my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Dr. Pendergrass,
https://app.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct:::06&cs=9c&.
999 ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. (located in West Liberty, KY) will be
solidifyin~
GP130
If you have any input on this matter please contact Mr. Frame at the e-ma ii address provided
son.r.frame@wv.gov ).
Frankfort, KY 40601
Ph~ 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP131
-m:
Sent:
To:
Subject:
Attachments:

Fairmont Brine plan.pdf; KRS 224.46-530_statute.pdf
Lindsey;
Just wanted to keep you informed related to the correspondence I am receiving on TENORM.
Thank you,
George


Hello Matt,
# _ k s like we have TENO RM contaminated hydraulic fracturing waste generated in WV being disposed of here at a
(http://www.adva nceddisposa I.com/ky/irvine/blue-ridge-landfill ) :

Irvine, KY 40336
Fax: 606-723-5607
General Manager
Phone: 606-975-7053
TENORM regs .
. . . .e know if you have time here in the next few weeks and I will arrange a meeting with EEC to d iscyss this issue.
Thanks,
GP132

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
~-~-'\l\Lebs1te.:http:L/wJt1YJ..chfs.ky,govfdphfradioactive.htm ~-----
Dispose of un!"anted sources http://www.crcpd.org/StateServices/SCATR.aspx

Level of radioactivity. Exposure rates were between 500 uRfhr and 2 mRfhr
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
GP133
&..
"'W
,....,t:

~: Frame, Jason R
Jason;
TENORM disposal.

~ow some of the above items we discussed in our conversation but I was so floored with the news I want to be sure I
George
(jeorge P. PartrUfee Jr., Pfi'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP134


--350. CapitoLStr:eetrRoom-31i_____
. ----------- -------~----- -~--------------~-----------------~------~- --~--
Office: (304)356-4303
Fax: (304) 558-0524
-----------'
To: Frame, Jason R


Hello Mr. Frame,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http:Uwww.chfs.kv.gov/dph/radioactive.htm
4
GP135

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
""ail: Jason.R.Frame@WV.gov

To: Frame, Jason R
Hello Mr. Frame,
rated in the oil and gas industry from hydraulic fracturing, we do have statutes on the books establishing the Central
est Interstate Low Level Radioactive Waste Compact of which KY is a member with IL. The compact strictly forbids
isposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously
GP136
is required.
Regards,
Mailstop HSlC-A
~~~~-Erankfod:,J{'lA062 L
Telephone: 502-564-3700 ext. 4183

Fax: 502-564-1492
herein.

Dr. Pendergrass,
inquiring about a West Virginia company's intent to dispose of TNORM from a "tracking" operation here i.n Kentucky by
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP137
-m:
Sent:
To:
Subject:
Attachments:

Lindsey;
Response to my questions from Jason Frame with WV.gov.
Thank you,
George

Brine
attatchment


Office: (304)356-4303
Fax: (304) 553..:0524
GP138

To: Frame, Jason R
Jason;
TENORM disposal.

Thanks again for all the time you devoted to corresponding and following up.with us.
George
<;jeorge P. PartridiJe Jr., Pfi'D, P.'E., Q,'EP

2
GP139

Frankfort, KY 40601
" " 2 ) 564-6716 ext. 4651


Office: {304)356-4303
Fax: {304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
TENORM Services of Liberty, KY {http://advtenorm.com/ ). We will follow up with the company's president, Cory
_ _ ins, and ascertain the nature and extent oftheir activities. We will also reach out to our colleagues in the Energy
t!J"""Environment Cabinet Division of Waste Management since they regulat~ landfills here in KY.
3
GP140

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
___._J.llLehslte_;JJttp~//www.chfs.ky.go\lldph/radioactive.htm . --------------.---------H---~-~---Pay your fees on line at https://prd.chfs.ky.gov/rad epay/
Dispose of un!'anted sources http://www.crcpd.org/StateServices/SCATR.aspx
__
------~---~------~~~
z>!......,.,,.~
n"Zh.a':t.~
P.ft,fJ!A11-ti'l1H~U.'fH


Mr. Pendergrass,
Jason R. Frame B.S. R. T. {R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
4
GP141
A..
"W
, , , Mr. Frame,
regulatory puiview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM/TENORM
is required.
Regards,
Supeivisor, Radioactive Materials Section
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
~ressee(s) and its content is confidential and privileged. If you are not the
~=nded recipient or the person responsible for delivering the e-mail to the
herein.

Dr. Pendergrass,
using the services provided by Advanced TENORM Seivices L.L.C. (
https://app.sos.ky.gov/ftshow/(S(3Qyqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
999 ). From Mr. Frames understanding, Advanced TENORM Seivices L.L.C. (located in West Liberty, KY) will be solidifying
rds to whether or not we would allow the disposal of TM ORN from other states in the state of Kentucky or send it
k to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNORM
5
GP142
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
-e0ntaine0nfiElentia!.-inf0rmati0n-exempHromciisclosureuncier-applicable-law~IUhe-reader-of-this-messagais-110Uhe __ intendad_recipient,_y_ou_are_notifierUbaLaoy__~-
GP143
To:
Cc:
Subject:

McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Perry, Eric D
(CHFS Rad Hlth); Bhattacharyya, Anjan
George, My staff and I would be happy to accompany you on your visit to Advanced TENO RM Services in West Liberty,
KY. We have all the radiation detection equipment that you need. With a reported exposure rate of up to 2 mR/hr on
the loads from WV, this material or the locations where it was processed and packaged for disposal should be fairly easy
to detect. We also have hand-held radioisotope identification devices {RI IDs) that we can bring along to confirm the ID
as Ra-226. I would love to take a few samples for our Environmental Monitoring lab to analyze as well to determine the
actual activity concentration. We also have several spare survey meter sets with general purpose alpha, beta and
gamma detectors which you are more than welcome to borrow. We can give you training on the meter sets as well. I am
scheduled to teach a radiological response course to the Shelbyville Fire Dept. on Thursday and Saturday so I
unfortunately will not be able to join you on your trip to West Liberty. However, I will see if I can't get one of my staff to
accompany you or at least meet up with you at Advanced TENO RM Services on Thursday. Looks like this might be the
impetus for finally getting us all moving on the TE NORM front.
~ntucky Radiation Health Branch
East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
rs
Krtl/11~
p,P,.tt'(t\T10N AAf-nuu.:rH

Hi Curt;
We are actively investigating the notice we received from Jason Frame {WV) that TENORM waste was disposed of here
entucky. I am also investigating three other companies in Ohio that we were informed of regarding TENO RM waste
osal in Kentucky.
..
I plan to be visiting landfills in eastern KV on Thursday of this week as well as visiting Advanced TENO RM Services located
in West Liberty.
1
GP144
It is unfortunate that I did not get the email messages that were sent to me last year or earlier this year in January since'
I am not familiar with monitoring for TE NORM. Are there detectors (portable, hand held, etc.) that could be made
waste would be treated before landfilling as well as the area where the waste would have been disposed of at the
waste as well which is not_rggulatedand has
~---site.__we_alsoieaJize_theJandfillsJnay_b_e.Le_c_e_btlng~stategenerated
been.--~--~~
Thanks for your help and interest as always,

George

Hello Matt,
(http://www.adva ncedd isposa I.com/ky/i rvi ne/bl ue-ridge-la ndfi 11 ) :

Irvine, KY 40336
Fax: 606-723-5607
General Manager
Phone: 606-975-7053
TENORM regs.
Thanks,
2
GP145

Mailstop HSlC-A
nkfort, KY 40621
: 502-564-3700 ext. 4183
Fax:502-564-1492
v...,..... t~
IW.t,,t/&~~
r-J;.tr1PCrmN.i1~irrr

'
Brine
Any knowledge where it was sent for solidification in Ashland, KY{?) prior to being sent to the landfill. See
attatchment

Office: {304)356-4303
Fax: {304) 558-0524
From: Partridge, George (EEC) [mailto:George.Partridqe@ky.gov]

3
GP146
To: Frame, Jason R

Jason;
TENORM disposal.
Services to Kentucky that'would be helpful.
-~~- ~-.
-----~-------~- --As much detail as possible will be helpful as we review manifests, etc. at the landfills.

George
<jeorge P. Partridge Jr., Pli'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

4
GP147

"'

Office: (304)356-4303
Fax: (304) 558-0524
..............., ,..,,..
_.....-.................,..,, ..,........... Jm: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]
nt: Tuesday, January 19, 2016 4:33 PM
To: Frame, Jason R
~-. ~ ~
Hello Mr. Frame,

Thank you for the follow-up e~mail on the purported disposition of WV TE NORM wastes here in KY by Advanced
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
,..aail: curt.pendergrass@ky.gov
~bsite: http:ljwww.chfs.ky.gov/dph/radioactive.htm
5
GP148
vi..,......~
l'\ffn~-:!J
1'.AOl.t\T~OitJli~AL TH


Mr. Pendergrass,

Office: (304)356-4303
Fax: {304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this e-
mail since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
is required.
6
GP149
Regards,
~Pendergrass, Ph.D.
9$up~rvisor,

Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

~: jason.r.frame@wv.gov
pbject: TNORM disposal in KY
Dr. Pendergrass,
back to the materials origins. I informed Mr. Frame that our office does no.t currently have regulation regarding TNORM
.Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
. . . .ICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
. . .tain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
GP150

Martin, Jerri (EEC)
To:
Cc:
Subject:
George,
226
228
Assuming an 8 hour work day and a total of 18 work days, the soil PRGs for Ra and
Ra are 198 and 74.7 pCi/g
respectively at a one in one million target risk. As you can see from the table below, changing the soil ingestion rate and
the number of days worked (exposure frequency) impacts the PRGs, but changing the slab size has hardly any impact on
the PRGs.
Jeri
Work
day hr
Target
risk
Slab size m
Exposure
Frequency
d/yr
Soil
ingestion
rate
mg/day
Inhalation
rate
3
m /day
acres
225Ra
22sRa
Soil PRG
Soil PRG
pCi/g
pCi/g
226
Ra Soil
PRG
mg/kg
lE-06
20
18
400
20
198
74.7
0.0002
3E-O:
lE-06
so
18
200
20
376
149
0.00038
SE-O:
lE-06
20
18
200
20
383
149
0.000388
SE-O:
lE-06
10
18
200
20
388
149
0.000392
SE-0:
lE-06
20
36
400
20
99.1
37.2
0.0001
1.4E-O:

To: Higginbotham, Jeri (EEC)

Jeri;
George

_jfject: RE: TNORM disposal in KY
Soil PRC
mg/kg
22sRa
GP151
-----
Brine
attatchment
Jason-R.-~ame-B.S.-R-1'.(R),-Chief-RadiologicaLHealth .. l!r.o.gram_.__
_____
....
~
-------~---~---- __ _

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.
Services_ to Kentucky that would be helpful.

2
GP152
r'1firmed the understanding we have of the situation before we move forward with site visits.
George
(jeor9e P. Partricf8e Jr., Pfi'D, P.'E., !2.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

.Jason R. Frame B.S. R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
..
GP153

To: Frame, Jason R

Hello Mr. Frame,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Vao(U~
l\f~l.-x:':!I.
r~11.01.P.Titll~lt\Hl'!>iJ.:rn

Mr. Pendergrass,
GP154
, v i s e on this issue. Thanks

Office: (304)356-4303
Fax: (304) 558-0524
om: Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]

nt: Tuesday, July 21, 2015 9:45 PM
.
: Frame, Jason R
Hello Mr. Frame,
is required.
Regards,
Mailstop HSlC-A
F nkfort, KY 40621
phone: 502-564-3700 ext. 4183
502-564-1492
5
GP155
herein.

Dr. Pendergrass,
https:Uapp.sos.ky.gov/ftshow/(S(30ygolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
999 ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. {located in West Liberty, KY) will be solidifying
the "facking" sludge in Ashland, KY and then sending it to a Class D landfill in Irvine, KV. Mr. Fame's question was in
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP156
f/tm:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney;
Please see the response I got below from Curt when I inquired if there were detectors that could be made available to
us.
How would you like to coordinate the site visits?
Curt doesn't realized that Advanced TENO RM Services in West Liberty is only an office location.
Should we narrow our site visits down and ask his staff to join us when we visit the landfills?
I am open for suggestions.
Let's get back with Curt tomorrow.
Thank you,
.orge

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Perry, Eric D (CHFS Rad Hlth); Bhattacharyya,
Anjan
George, My staff and I would be happy to accompany you on your visit to Advanced TENO RM Services in West Liberty,
to detect. We also have hand-held radioisotope identification devices (RllDs) that we can bring along to confirm the ID
accompany you or at least meet up with you at Advanced TE NORM Services on Thursday. Looks like this might be the
impetus for finally getting us all moving on the TE NORM front.
~tucky Radiation Health Branch
Mailstop HSlC-A
Frankfort, KY 40621
1
GP157
Tel: 502-564-3700 ext. 4183

Fax: 502-564-1492
3i1JA
VnnfU.
~t..-"'"'"''
. HAt!!ATIONHe>U.TH
GP158

Subject:
Jeri;
Thank you again for all the guidance and help you provided us on such short notice.
The analyses you provided gives us a helpful starting point as we seek to identify the potential impacts to human health.
Thanks again and have a nice afternoon!
George
From: Higginbotham, Jeri (EEC)


Cc: Martin, Jerri (EEC)
#orge,
226
228
Assuming an 8 hour work day and a total of 18 work days, the soil PRGs for Ra and
Ra are 198 and 74.7 pCi/g
the PRGs.
Jeri
Work
day hr
Target
risk
8
Slab size m
lE-06
Exposure
Frequency
Soil
ingestion
rate
d/yr
mg/day
20
18
Inhalation
rate
3
m /day
400
20
acres
1
226Ra
22sRa
Soil PRG
Soil PRG
pCi/g
pCi/g
198
226
74.7
22sRa
Ra Soil
PRG
mg/kg
Soil PRC
mg/kg
0.0002
3E-O:
0.00038
SE-O:
,,
lE-06
50
18
200
20
376
149
lE-06
20
18
200
20
383
149
0.000388
SE-O:
lE-06
10
18
200
20
388
149
0.000392
SE-O:
lE-06
20
36
400
20
99.1
37.2
0.0001
1.4E-O:

nt: Monday, February 01, 2016 12:17 PM
: Higginbotham, Jeri (EEC)

Jeri;
1
GP159

George
, -~-.l'o:-Rartr-idge,~Geor-ga{EEC)_
Name of company in Fairmont along with County that contracted with Advance.d TENO RM Services. Fairmont
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
'
From: Partridge, George (EEC) [mailto:Georqe.Partridqe@ky.gov]

To: Frame, Jason R
Jason;
GP160
TENORM disposal.
~ou could provide additional information related to our conversation about the shipments by Advanced TENO RM

Any knowledge where it was sent for solidification in Ashland, KY (?) prior to being sent to the landfill.
- o k forward to hearing from you!
George
<george P. PartridiJe Jr., Pfi1J, P.'E., fl'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP161
-m:

Sent:
To:
Cc:
Subject:
Jeri;
Thank you again for all the guidance and help you provided us on such short notice.
The analyses you provided gives us a helpful starting point as we seek to identify the potential impacts to human health.
Thanks again and have a nice afternoon!
George
Sent: Monday, February al, 2a16 3:43 PM

Cc: Martin, Jerri (EEC)

-orge,
226
228
Assuming an 8 hour work day and a total of 18 work days, the soil PRGs for Ra and Ra are 198 and 74.7 pCi/g
the PRGs.
Jeri
Work
day hr
Target
risk
Slab size m
Exposure
Frequency
d/yr
Soil
ingestion
rate
mg/day
Inhalation
rate
3
m /day
acres
22GRa
22sRa
Soil PRG
pCi/g
226
22sRa
Soil PRG
Ra Soil
PRG
Soil PR(
pCi/g
mg( kg
mg/kg
1E-a6
20
18
400
20
198
74.i
0.0002
3E-O:
1E-06
so
18
200
20
376
149
0.00038
SE-O:
1E-06
20
18
200
20
383
149
0.000388
SE-a:
1E-06
10
18
200
20
388
149
0.000392
SE-a:
1E-06
20
36
4aa
2a
99.1
37.2
o.aao1
1.4E-a:
t: Monday, February al, 2a16 12:17 PM

bject: FW: TNORM disposal in KY
Jeri;
1
GP162

George
From: Frame, Jason R [mailto:Jason.R.Frarne@wv.gov]

"~--~To!~Raltl"idge,"-Geoi:ge--(EEq. ___
. ~-~---~----~--~--~- ----~-------.
. ------- --------~~-~-
Subject:
R~: TNORM disposal in KY
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
GP163
TENORM disposal.
~ou could provide additional information related to our conversation about the shipments by Advanced TENORM

f#iok forward to hearing from you I

George
(jeorge P. PartridiJe Jr., Pfi1J, P.'E., Q'EP

Frankfort; KY 40601
(502) 564-6716 ext. 4651
,
3
GP164
fljom:
Sent:
To:
Subject:

Matt;
I am forwarding your message to Lindsey Briggs my supervisor.
George
KDWM
From: McKinley, Matthew W (CHS-PH)


I am open Feb 23, 24, 26, Mar 1, 2, 3. I agree that specific TENO RM regulations would go a long toward preventing this
have apparently violated .
;; r;;~ci;~~~~~~;c~rt.(cHFs.oPH) ..................... .

Hello Matt,
with WV (see attached). The work was done by Advanced TE NORM services in West Liberty, KY
(http:Uwww.advanceddisposal.com/ky/irvine/blue-ridge-landfill ):
..

Irvine, KY 40336
Fax: 606-723-5607
General Manager
Phone: 606-975-7053
1
GP165
TENORM regs.
Thanks,
; _______Ke ntucky_RadiationJ-lealth_Hranch ____~--_____ -----~--~--~-- ________________ _
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Ktz1!Yii!J~
HA!'Jl.i\'r!Ol'l a~JJ;p,L:rtl

Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
GP166

To: Frame, Jason R
Jason;
TENORM disposal.
much detail as possible will be helpful as we review manifests, etc. at the landfills.

-rge
(jeorge P. Partridge Jr., Pfi'D, P.'E., Q.'EP

3
GP167

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: {304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,
Hoskins, and ascertain the nature and extent of their activities. We will also reach o~t to our colleagues in the Energy

4
GP168

. 5 East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky .gov Id ph/rad ioactive .htm
Pay your fees on line at https://prd.chfs.ky,gov/rad epay/
Dispose of ur~anted sources http://www.crcpd.org/StateServices/SCATR.aspx
... >;;

Mr. Pendergrass,
erating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please
vise on this issue. Thanks

Office: (304)356-4303
Fax: (304) 558-0524
GP169
Hello Mr. Frame,
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this e-
-~---mail-sinc~disposaL0Lwastes~ontainingJlaza~dous-mater'ialsJncluding~NORM/IENOB.l'1Lin~landfiUs-her_eJn_KY~isJ:beir~.~~
is required.
Regards,
. Supervisor, Radioactive Materials Section
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Dr. Pendergrass,
999 ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. {located in West Liberty, KY) will be solidifying
back to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNORM.
6
GP170

dioactive Materials Section
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only tor the use of the individual or entity to which it is addressed and may
GP171
-om:
Sent:
To:
Subject:

George, Just let us know what time works best for you in the weeks in February and March that Matt has
mentioned. Monday March 1st is a good day for me as is the whole week of February 22-26. We have a couple of NRC
webinars in the afternoon on Feb 23rd and 25th but the mornings are wide open that week. Whatever works best for you
and your team. We can meet at our office here in DPH or else we could come to your shop.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~ebsite: http://www.chfs.ky.gov/dph/radioactive.htm
. .Y your fees on line at https://prd.chfs.ky.gov/rad epay/
zltntu~I
IV
...........~1$i~
r~1u..rlJrrJOtiAHEictrri


I am open Feb 23, 24, 26, Mar 1, 2, 3. I agree that specific TENO RM regulations would go a long toward preventing this

-oMatt,
Looks like we have TENORM contaminated hydraulic fracturing waste generated in WV being disposed of here at a
1
GP172
(http://www.advanceddisposal.com/ky/irvine/blue-ridge-landfill ):

Irvine, KY 40336
Fax: 606-723-5607
--
----
-----~----ueneral1Yfariager-~~---~------~--~--~--~-----~~---~-~------ ~-----------~~- -----~-
Emai I: Charles.Laws@AdvancedDisposal.com
Phone: 606-975-7053
governing waste disposal including KRS 224.46-530, (1)(k). I think that it is time that we sit down with Dr. George
TENORM regs.
Thanks,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
KepJM(!{y~
ttA!:r-lJ.\Tltll''1H!!Al.:HI

2
GP173
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
~;:-Partridge,
George (EEC) [mailto:George.Partridge@ky.gov]

To: Frame, Jason R
Jason;
TENORM disposal.

GP174
Look forward to hearing_frgm_Yl>J.IL __ ~ __
---------~~
George
(jeorge P. Partricfae Jr., Pfi'D, P.'E., Q;EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
GP175

~nt: Tuesday, January 19, 2016 4:33 PM
~: Frame, Jason R
Hello Mr. Frame,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
bsite: http://www.chfs.ky.gov/dph/radioactive.htm
your fees on line at https:Uprd.chfs.ky.gov/rad epay/
Dispose of ur~anted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx

Mr. Pendergrass,
.Jason R. Frame B.S. R.T. (R), Chief Radiological Health Program

. Charleston, West Virginia 25301
..A:e: (304)356-4303
~: (304) 558-0524
GP176


To: Frame, Jason R
Hello Mr. Frame,

contaminated waste so Advanced TENORM Services might want to check with the authorities in those states to see what .
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

6
GP177
To: Pendergr'!SS, Curt (CHFS DPH)

_.ubject: TNORM disposal in KY
~r. Pendergrass,
inquiring about a West Virginia company's intent to dispose of TN ORM from a "tracking" operation here in Kentucky by
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
~rmtain confidential information exempt from. disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
1iew, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
nder by r~ply e-mail and destroy all copies of the original message.
GP178

Tuesday, February 02, 2016 7:33 AM
Maze, Rodney (EEC)
To:
Subject:
Rodney;
My thoughts are to focus on the landfills that we have been told that TE NORM waste is going to, not worry about
company the office if Curt's staff is with us.
If Curt's staff does not join us, do we have the equipment to detect TENORM adequately?
I will get with Jon and get his recommendations for us.
Thank you,
George

,,bject:
Re: TNORM disposal in KY
Speak with Jon Maybriar about this and get his option
Thanks
Rodney Maze
On Feb 1, 2016, at 3:44 PM, Partridge, George (EEC) <George.Partridge@ky.gov> wrote:

Rodney;
Please see the response I got below from Curt when I inquired if there were detectors that could be
made available to us.
Curt doesn't realized that Advanced TENORM Services in West Liberty is only an office location.
Should we narrow our site visits down and ask his staff to join us when we visit the landfills?
..

Let's get back with Curt tomorrow .
Thank you,
GP179
George

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Perry, Eric D (CHFS Rad Hlth);
Bhattacharyya, Anjan
George, My staff and I would be happy to accompany you on your visit to Advanced TENO RM Services in
---------West Liberty, KY. Wehave allthe-radiation-deteC:tionequipment that you-need. With a- reported.
exposure rate of up to 2 mR/hr on the loads from WV, this material or the locations where it was
processed and packaged for disposal should be fairly easy to detect. We also have hand-held
radioisotope identification devices (RllDs) that we can bring along to confirm the ID as Ra-226. I would
love to take a few samples for our Environmental Monitoring lab to analyze as well to determine the
actual activity concentration. We also have several spare survey meter sets with general purpose alpha,
beta and gamma detectors which you are more than welcome to borrow. We can give you training on
the meter sets as well. I am scheduled to teach a radiological response course to the Shelbyville Fire
Dept. on Thursday and Saturday so I unfortunately will not be able to join you on your trip to West
Liberty. However, I will see if I can't get one of my staff to accompany you or at least meet up with you
at Advanced TENORM Services on Thursday. Looks like this might be the impetus for finally getting us all
moving on the TENO RM front.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
<image001.jpg>
GP180
Partridge, George.(EEC)
-om:
Sent:
To:
Subject:

Maybriar, Jon (EEC)
Tracking:
Recipient
Delivery
Read
Maybriar, Jon (EEC)
Read: 2/2/2016 8:06 AM
Jon:
Please find correspondence below from Curt Pendergrass. TENO RM is being disposed of in Kentucky from out of state
and Rodney Maze and I plan to visit the sites we have been told by individuals in Ohio and WV that are accepting
TENORM waste.
Curt Pendergrass would like to have staff join us so we can confirm that TE NORM has been accepted by these sites.
would like to meet with you to bring you up to date on what is going on, the contacts others have made with me, and
your guidance on how you would like to approach this.
I will be at 300 Fair Oaks with Ken Melton this morning and ask that you call me on my cell phone if you get this message
and can respond before 10:30 AM. I feel it is important we meet today and I would appreciate your guidance very
much .
ankyou,
George
859-221-8843

,,,
West Liberty, KY. We have all the radiation detection equipment that you need. With a reported
at Advanced TE NORM Services on Thursday. Looks like this might be the impetus for finally getting us all
1
GP181

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~------~-~--~--- _Wehsite:_bttp.:f!wwwLchf.k'L.gO'.iLLd phLradioactbte. htm ___ ---~---. .____.____._________________________ ~----------------~----- __
<image001.jpg>
GP182
#om:
Maze, Rodney (EEC)

Sent:
To:
Subject:
Sounds like a good plan. Do I still need to get the detectors from ERT, it would probably next week
Rodney Maze

Rodney;
My thoughts are to focus on the landfills that we have been told that TENORM waste is going to, not
worry about company the office if Curt's staff is with us.
If Curt's staff does not join us, do we have the equipment to detect TENO RM adequately?
Thank you,
George

Subject: Re: TNORM disposal in KY
Thanks
Rodney Maze

Rodney;
Please see the response I got below from Curt when I inquired if there were detectors
that could be made available to us.
Curt doesn't realized that Advanced TENO RM Services in West Liberty is only an office
location.
GP183
Should we narrow our site visits down and ask his staff to join us when we visit the
landfills?
Thank you,
___ __ __ _____ ______ Gemge________________---~~-------_________________-----------------~-~----- -~-----~---~- ------ ------------------------------------

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Perry, Eric D
George, My staff and I would be happy to accompany you on your visit to Advanced
TENORM Services in West Liberty, KY. We have all the radiation detection equipment
that you need. With a reported exposure rate of up to 2 mR/hr on the loads from WV,
this material or the locations where it was processed and packaged for disposal should
be fairly easy to detect. We also have hand-held raldioisotope identification devices
(RllDs) that we can bring along to confirm the ID as Ra-226. I would love to take a few
samples for our Environmental Monitoring lab to analyze as well to determine the
actual activity concentration. We also have several spare survey meter sets with general
purpGse alpha, beta and gamma detectors which you are more than welcome to
borrow. We can give you training on the meter sets as well. I am scheduled to teach a
radiological response course to the Shelbyville Fire Dept. on Thursday and Saturday so I
unfortunately will not be able to join you on your trip to West Liberty. However, I will
see if I can't get one of my staff to accompany you or at least meet up with you at
Advanced TENO RM Services on Thursday. Looks like this might be the impetus for finally
getting us all moving on the TENORM front.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http ://www.chfs.ky.govI dph/rad ioactive. htm
<image001.jpg>
GP184
'#om:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney;
If we go this week and we do not get detectors from Curt, does this mean that we would be going to the sites without
any means of screening for the presence of TE NORM?
George

Sent: Tuesday, February 02, 2016 8:02 AM
Rodney Maze
Feb 2, 2016, at 7:32 AM, Partridge, George (EEC) <George.Partridge@ky.gov> wrote:

Rodney;
My thoughts are to focus on the landfills that we have been told that TENORM waste is going to, not
worry about company the office if Curt's staff is with us.
If Curt's staff does not join us, do we have the equipment to detect TE NORM adequately?
Thank you,
George

Thanks
"
Rodney Maze

1
GP185
Rodney;
Please see the response I got below from Curt when I inquired if there were detectors
that could be made available to us.
Curt doesn't realized that Advanced TE NORM Services in West Liberty is only an office
location.
Should we narrow our site visits down and ask his staff to join us when we visit the
landfills?
Thank you,
George

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Perry, Eric D
Subject: RE: TNORM disposal in KY ,
George, My staff and I would be happy to accompany you on your visit to Advanced
TENORM Services in West Liberty, KY. We have all the radiation detection equipment
that you need. With a reported exposure rate of up to 2 mR/hr on the loads from WV,
this material or the locations where it was processed and packaged for disposal should
be fairly easy to detect. We also have hand-held radioisotope identification devices
(RI IDs) that we can bring along to confirm the ID as Ra-226. I would love to take a few
samples for our Environmental Monitoring lab to analyze as well to determine the
actual activity concentration. We also have several spare survey meter sets with general
purpose alpha, beta and gamma detectors which you are more than welcome to
borrow. We can give you training on the meter sets as well. I am scheduled to teach a
radiological response course to the Shelbyville Fire Dept. on Thursday and Saturday so I
unfortunately will not be able to join you on your trip to West Liberty. However, I will
see if I can't get one of my staff to accompany you or at least meet up with you at
Advanced TENO RM Services on Thursday. Looks like this might be the impetus for finally
getting us all moving on the TENORM front.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
2
GP186
<image001.jpg>
..
3
GP187

Maze, Rodney (EEC)
That's correct
Rodney Maze

Rodney;
If we go this week and we do not get detectors from Curt, does this mean that we would be going to the
sites' without any means of screening for the presence of TE NORM?
George
Sent: Tuesday,
1
February 02, 2016 8:02 AM

Rodney Maze

Rodney;
My thoughts are to focus on the landfills that we have been told that TENORM waste is
going to, not worry about company the office if Curt's staff is with us.
If Curt's staff does not join us, do we have the equipment to detect TENORM
adequately?
Thank you,
George

1
GP188
Thanks
'
Rodney Maze

____-~----~-~-----~-~ Rodney_;___________________________________ ---~---------------------------Please see the response I got below from Curt when I inquired if there
were detectors that could be made available to us.
Curt doesn't realized that Advanced TENO RM Services in West Liberty is
only an office location.
Should we narrow our site visits down and ask his staff to join us when
we visit the landfills?
'
Thank you,
George

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad
Hlth); Perry, Eric D (CHFS Rad Hlth); Bhattacharyya, Anjan
George, My staff and I would be happy to accompany you on your visit
to Advanced TENORM Services in West Liberty, KV. We have all the
radiation detection equipment that you need. With a reported exposure
rate of up to 2 mR/hr on the loads from WV, this material or the
locations where it was processed and packaged for disposal should be
fairly easy to detect. We also have hand-held radioisotope identification
devices (RllDs) that we can bring along to confirm the ID as Ra-226. I
would love to take a few samples for our Environmental Monitoring lab
to analyze as well to determine the actual activity concentration. We
also have several spare survey meter sets with general purpose alpha,
beta and gamma detectors which you are more than welcome to
borrow. We can give you training on the meter sets as well. I am
scheduled to teach a radiological response course to the Shelbyville Fire
Dept. on Thursday and Saturday so I unfortunately will not be able to
join you on your trip to West Liberty. However, I will see if I can't get
one of my staff to accompany you or at least meet up with you at
2
GP189
Advanced TE NORM Services on Thursday. looks like this might be the

impetus for finally getting us all moving on the TENORM front.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Pay your fees on line at https://prd.chfs.ky.gov/raCI epay/
Be notified of proposed regulation changes
https://secure. ke ntucky.gov/Regwatch/
Dispose of unwanted sources
http://www.ere pd .o rg/StateServices/SCATR.aspx
<imageOOl.jpg>
..
3
GP190
#m:
Sent:
To:
Subject:
Maybriar, Jon (EEC)

George,
Call me please when you get a chance. Thanks

To: Maybriar, Jon (EEC)
Jon:
Please find correspondence below from Curt Pendergrass. TENO RM is being disposed of in Kentucky from out of state
and Rodney Maze and I plan to visit the sites we have been told by individuals in Ohio and WV that are accepting
TENORM waste.
Curt Pendergrass would like to have staff join us so we can confirm that TENORM has been accepted by these sites. I
~ould like to meet with you to bring you up to date on what is going on, the contacts others have made with me, and
~ur guidance on how you would like to approach this.
I will be at 300 F.air Oaks with Ken Melton this morning and ask that you call me on my cell phone if you get this message
and can respond before 10:30 AM. I feel it is important we meet today and I would appreciate your guidance very
much.
!hank you,
George
859-221-8843

..
West Liberty, KY. We have all the radiation detection equipment that you need. With a reported
1
GP191
at Advanced TE NORM Services on Thursday. Looks like this might be the impetus for finally getting us all

-----~--------27-5_EastMain5treet __ ~~~- ----~-"--~- -------~----
Ma ilstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<image001.jpg>
GP192
tl_rom:
Sent:
To:
Subject:

Maze, Rodney (EEC)
RE: Visits to Investigate TENORM
Rodney;
I spent yesterday running some risk assessment calculations on TE NORM based on the levels of radiation emitted from
the source we were notified as receiving from WV. I am not going to go looking for TENORM waste at a site without any
type of monitoring or detection equipment with me.
I spoke with Jon this morning. He only wants us to visit the site and learn what we can without involvement from Curt's
group at this point.
I am glad to join you to meet with facility personnel or review manifests, etc. regarding records of waste received. Also
Jon mentioned to find out the status of their radiation detectors (detection level, calibration status, maintenance, etc.).
Also Big Run is eliminating two of their solidification pits, moving the other two (?) and presently Weaver Consultants is
finalizing the design for the ones they are relocating. In the future if they did received any TENO RM, any traces of it will
be eliminated or covered up.
, a n k you for what you are doing.
I have vehicle reserved for Thursday and am glad to join you.
The management both in the Hazardous Waste Branch and the Solid Waste Branch is suggesting we send out "courtesy
letters" reminding landfills and Advanced TENO RM Services they are not to be receiving TENO RM waste from out of
state. That is the only recommended action that is being suggested at this time.
I feel I am overstepping the desires of upper management by pursuing TENORN to the'extent I have and at this point feel
I need to just focused on my assigned job duties and only be available to work on things when requested by my
supervisor, Lindsey Briggs.
We were able to do things at Big Run because of the political pressures facing that site. This is not the case for TENO RM
disposal which will impact the eastern part of the state that is economically depressed. With the regulations in Ohio,
WV, and PA - Kentucky is positioned to dispose of this waste very cost effectively for the tracking and O&G industry, and
I am reminded we do not regulate its disposal within our state. All we are doing is reducing some potential business
from out of state when we are already disposing of it within our state. Also how are we going to distinguish between
sources?
I will plan on Thursday if you still want to move forward with the visits. At this point I only want to do what is requested
of me by management.
Thank you,
fl/trge
George P. Partricfee Jr.

1
GP193

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP194
Cc:
Subject:

Tuesday, February 02, 2016 12:40 PM
McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Perry, Eric D
Hello George,
Mr. Chris Keffer from my office has volunteered to assist you at your inspection of Advanced TE NORM Services in West
Liberty on Thursday. Chris will be bringing his rad survey meter set as well as a radioisotope identification device. Chris
worked in our lab for several years and he will also be bringing along supplies to take samples and bring them back to
the lab for radioanalytical analysis. Chris's contact information is as follows:
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
E-mail: Christopher.Keffer@ky.gov
A couple of things that my staff have brought to my attention regarding this matter that might interest you and your
colleagues in EEC. One is that we now have the ability to charge full cost reimbursement for our site investigations and
secondly, the Central Midwest Compact of which KY is a member with IL, specifically prohibits the import of NORM from
outside KY for disposal. From everything I have seen and heard, Advanced TE NORM Services in West Liberty is guilty of
violating this statute and subject to penalties and should be billed for our site visits. I will let you and Chris work out the
logistics of this site visit between yourselves.
Regards,
Curt
902 KAR 100:012. Fee schedule. http://www.lrc.state.ky.us/kar/902/100/012.htm

Section 5. Site Investigations, Remediation Projects, and Scoping Surveys. The licensee, remediation contractor,
or other responsible party shall provide full cost reimbursement for review and oversight of site investigations,
remediation projects, and scoping surveys to include project evaluation and planning, sample collection, analysis,
and independent validation as applicable.
211.863 Control of commerce of low-level radioactive waste in and out of Kentucky

-- Prohibitions -- Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id=8502
..
(3) Naturally-occurring radioactive material (NORM) as defined in KRS 211.862(8)

shall be the exclusive regulatory responsibility of the states, except that no person
shall import naturally occurring radioactive material (NORM) from outside the
region for disposal in Kentucky, or dispose of such imported material in Kentucky,
if the imports or disposal are inconsistent with polices of the commission.
1
GP195
211.869 Penalties. http://www.lrc.ky.gov/statutes/statute.aspx?id=8505

(1) Any person who fails to comply with any provision of KRS 211.859 or 211.863, or
with any administrative regulations promulgated pursuant to KRS 211.859 or
211.865, or fails to comply with any order of the cabinet issued pursuant to KRS
211.859 or KRS 211.863 and 211.865 shall be assessed a civil penalty not less than
ten thousand dollars ($10,000) nor more than one hundred thousand dollars
($100,000). Each day of the violation or noncompliance shall constitute a separate
offense.
------- --2l-1~862-I>efinitions-for-K~S~2-1-h861-to-2+h869""------0--------~- ------------- --------------------

http://www.lrc.ky.gov/statutes/statute.aspx?id=8501
(8) "Naturally-occurring radioactive material" (NORM) means naturally occurring
materials not regulated under the Atomic Energy Act of 1954, as amended, whose
radionuclide concentrations have been increased by or as a result of human
practices. Naturally occurring radioactive material does not include the natural
radioactivity of rocks or soils, or background radiation, but instead refers to
materials whose radioactivity is technologically enhanced by controllable practices
(or by past human practices);

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564~1492
E-:rnail: curt.pendergrass@ky.gov
Dispose of u~anted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
'Vnn(U{Jfl~
'Et-~~!Y
:f'AtiU\TlOtitAHEAl'fFI

Cc: McKinley, Matthew W (CHS-PH) (MatthewW.McKinley@ky.gov); Keffer, Christopher (CHFS Rad Hlth)
(Christopher.Keffer@ky.gov); Perry, Eric D (CHFS Rad Hlth) (EricD.Perry@ky.gov); Bhattacharyya, Anjan
(Anjan.bhattacharyya@Ky.Gov)
George, My staff and I would be happy to accompany you on your visit to Advanced TE NORM Services in West Liberty,
to detect. We also have hand-held radioisotope identification devices (RI IDs) that we can bring along to confirm the ID
2
GP196
accompany you or at least meet up with you at Advanced TENORM Services on Thursday. Looks like this might be the
.mpetus for finally getting us all moving on the TENORM front.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564~1492
Be notified of proposed regulation changes https:/Lsecure.kentucky.gov/Regwatch/
VafffU~
~'~~~~
, fJ,!JlATlOiti\H~.tlr!

.Curt;
We are actively investigating the notice we received from Jason Frame (WV) that TENO RM waste was disposed of here
in West Liberty.
I am not familiar with monitoring for TENO RM. Are there detectors (portable, hand held, etc.) that could be made
site. We also realize the landfills may be receiving in-state generated waste as well which is not regulated and has been
9!!';;ep~~de;grass,
Curt (CHFS DPH')''' ,,,,,,,,,,,,,,,,

L_,
GP197
Hello Matt,
looks like we have TENO RM contaminated hydraulic fracturing waste generated in WV being disposed of here at a
with WV (see attached). The work was done by Advanced TENORM services in West liberty, KY
______ search turned up the foJlg~ing landfill in Irvine run by Advanced Disposal
(http://www.advanceddisposal.com/ky/irvine/blue-ridge-landfill):________________ ------------------ ------------~-~~-~-~-----------
Blue Ridge Landfill - lrvine, KY

Irvine, KY 40336
Fax: 606-723-5607
General Manager
Phone: 606-975-7053
TENORM regs.
let me know if you have time here in the next few weeks and I will arrange a meeting with EEC to discuss this issue.
Thanks,

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564~3700 ext. 4183
Fax: 502-564-1492
Be notified of proposed regulation changes https;//secure.kentucky.gov/Regwatch/
KtZt

4
GP198
The form or appearance of the waste when it was shipped (b~fore solidification). What does it look like?
Brine
attatchment

Office: {304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.
If youcould provide additional information related to our conversation about the shipments by Advanced TENO RM
-rmation such as:

5
GP199
George
(jeorge 'P. Partrirlge Jr., PfiV, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
GP200
From: Pendergrass, Curt (CHFS DPH) [maifto:Curt.Penderqrass@ky.gov]

To: Frame, Jason R

Hello Mr. Frame,
and Environment Cabinet Division of Waste Management since they regulate landfills here in KY .
hanks again for reaching out to me regarding this matter.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of un!"anted sources http:l/www.crcpd.org/StateServices/SCATR.aspx
m . .. '
'1.,.,..
~
l~t..-fJJl,!JJjfriOit&,H~tl.TH
. To: Pendergrass, Curt (CHFS DPH)
_Jjibject: RE: TNORM disposal in KY
. Pendergrass,
GP201
operating as" Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
--~Fa~+-(-384-)--58-Q.24~~~
To:
Frame, Jason R
Hello Mr. Frame,

is required.
Regards,
Mailstop HS.lC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
This e-mail and any fil~s are protected by the Electronic Communications Privacy
8
GP202
~hat any use, dissemination, forwarding, printing, or copying of this e-mail is
9"prohibited. If you have received this e-mail in error, please notify the sender
herein.

Subject: TNORM ~isposal in KY
Dr. Pendergrass,
999 ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. (located in West Liberty, KV) will be solidifying
the "tacking" sludge in Ashland, KY and then sending it to a Class D landfill in Irvine, KV. Mr. Fame's question was in
~
W'nason.r.frame@wv.gov ).
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable Jaw. If the reader of this message is not the intended recipient, you are notified that any
GP203

m:
Sent:
To:
Subject:

Curt;
I am not really part of a team, but an individual like you who is seeking to make the world a safer and healthier place for
all. As I see the issues of TENO RM arise I have been pushing hard, maybe too hard from within my Division to encourage
us to address them, particularly as other states surrounding us are doing so. This all started with our correspondence in
past years where we were concerned that Kentucky would become a dumping ground for TE NORM if other states
prohibited the waste from being disposed in their states and we did not regulate TENORM within our state. We are at
that point.
What has been pointed out to me is that TE NORM is being disposed of in this state. We do not regulate disposal within
this state. The initiatives we are pursuing to restrict out of state waste is only reducing the business of companies like
Advanced TENORM Services.
http://advtenorm.com/
I have heard indirectly that our Division Director is having someone look at the regulations and get familiar with
, O R M but I am not part of that initiative, or at least not at this point.
At this point all I am to do is to talk or meet with individuals at landfills and look at their records or manifests to confirm
if TENORM is being received. No meetings or monitoring at this time, only talking to others as coordinated by our field
officer perspnnel.
It also has been suggested by both the Solid Waste Branch and the Hazardous Waste Branch that we send "courtesy
letters" reminding our landfills and Advance TEN ROM Services they are not to dispose of waste from out of state.
I do not feel we can do anymore at this time.
By the way from what I understand, Advanced TENO RM Services is only an address in a residential area in West Liberty
and all work is subcontracted out.
At this point, I will need to wait until I get instruction or direction from my management before I proceed further.
Thanks again for all you are doing!
George
.-ject:

George, Just let us know what time works best for you in the weeks in February and March that Matt has
mentioned. Monday March 1st is a good day for me as is the whole week of February 22-26. We have a couple .of NRC
1
GP204
webinars in the afternoon on Feb 23rd and 25th but the mornings are wide open that week. Whatever works best for you
and your team. We can meet at our office here in DPH or else we could come to your shop.
Regards,
-=--~-"--=~~~Ma_ilsto_pJ:iS_lC~------------------~-
___ --------~------ ____ -----0=-.--'-~--=--------
Fra n kfort, KY 40621

Tel: 502-564-3700 ext. 4183
Fax'. 502-564-1492
v.b....mflk~
~:~~~~
f1Jii!.J'lt\"ribt1Jb1"!Mt.:n1

I am open Feb 23, 24, 26, Mar 1, 2, 3. I agree that specific TENORM regulations would go a long toward preventing this
Hello Matt,

Irvine, KY 40336
Fax: 606-723-5607
General Manager
..
GP205

Phone: 606-975-7053
e ! s is an obvious violation of the Central Midwest Compact, our regulations and not to mention EEC regulations
governing waste disposal including KRS 224.46-530, (1)(k). I think that it is time that we sit down with Dr. George
TENORM regs.
Let me know if you have time here in the next few weeks and I will arrange a meeting with EEC todiscuss this issue.
Thanks,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492

. Level of radioactivity. Exposure rates were between 500 uR/hr and 2 mR/hr
Brine
attatchment
e of Environme. ntal .Health Services/Radiation, Toxics and Indoor Air Division

apitol Street, Room 313
eston, West Virginia 25301
Office: (304)356-4303
Fax: (304) 558-0524
3
GP206

To: Frame, Jason R

Jason;
TENORM disposal.

George
GP207
(ieorge P. PartridiJe Jr., Pn'D, P.'.E., Q'.EP

Division of Waste Management
- Fair Oaks Lane; 2nd Floor (SWB)
I
Frankfort, KY 40601
(502) 564-6716 ext. 4651
.a
From: Frame, Jason R [mailto:Jason.R.Frame@WV.gov]


,.,,jjjice: (304)356-4303
~: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
- n k you for the follow-up e-mail on the purported disposition of WV TENO RM wastes here in KY by Advanced
5
GP208

Mailstop HSlC-A
Frankfort, KY 40621
-----~J_eJ:5U2.::5_64-3-20Jl.e_i~t.-~_L8_i__~--~---- -------~- ~---- ---~-
______ _____
Fax: 502-564-1492
Dispose of un!'anted sources http:Uwww.crcpd.org/StateServices/SCATR.aspx
Kt!/!J4 - -


Mr. Pendergrass,
Jason R. Frame B.S. R. T. (R}, Chief Radiological Health Program

Office: {304)356-4303
Fax: (304) 558-0524
GP209

Frame, Jason R
Webb, April (EEC); George.Patridqe@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Hello Mr. Frame,

Midwestlnterstate Low Level Radioactive Waste Compact of which KY is a tnember with IL The compact strictly forbids
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
502-564-1492
....&:
- s e-mail and any files are protected by the Electronic Communications Privacy
herein.

Dr. Pendergrass,
inquiring about a West Virginia company's intent to dispose ofTNORM from a "fracking" operation here in Kentucky by
s: a .sos.k . ov ftshow S 30 olkfdaebcz4h oreem 4 default.as x? ath=ftsearch&id=0904260&ct=06&cs=99
_ ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. (located in West Liberty, KY) will be solidifying
7
GP210
......
.
.
Frankfort, KY 40601
----Ph:~so2-564--3'700-x4-1-79----------- ---~--~-.------------- ------~----~~-- ~--~~--~~~~~~---~-~-Cell: 502 330-7662
FAX: 502-564-1492
review, use, disclosure, distribution or copying of this communication is strictly prohibited, If you have received this communication in error, please contact the
GP211
Cc:
Subject:

Hello again George,

Based on your e-mail below, am I to presume you will not be making a trip down to West Liberty this week? And if you
are correct that Advan.ced TENORM Services West Liberty address (151 University Drive, West Liberty, KY 41472) is
nothing more than a residential address, then making a trip down to West Liberty is probably a waste of time anyway.
But I have to tell you, I Googled the address and it clearly shows a large industrial building on the satellite image, very
similar to what I would expect to see for a business engaged in this type of industry.
https://www.google.com/ma ps/place/151 +University+Dr, +West+Liberty, +KY+41472/@37 .9006415, 83.2914827,614m/ data= !3m2!1e3 !4b1 !4m2!3m1!1s0x8844671c5d97 ce5b:Ox7b555a421ea91024
The aerial view does not look like the photo shown on their website (http://advtenorm.com/services/) but that photo
might be a picture of one of their clients, and the ATS facility in West Liberty. In fact looking at the photo, this looks
more like an oil storage facility and not a TENORM processing facility. But either way, we are still ready, willing and able
to make a trip to West Liberty on Thursday. And if there is anything I can do raise the level of significance of this issue
with your superiors, I will be more than happy to do. Let us know how you wish to approach this.

Supervisor, Rad)oactive Materials Section
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
' ~502-564-1492
'
ii: curt.pendergrass@ky.gov
..
GP212
.
.
Obi.m....:!I
.
~
..~ .. ~.:
..
f.T(r~
f~,tHATiOl'iMtii-U. TH
Sent: Tuesday, February 02, 2016 1:05 PM

I-
---urt~-----~~---'--~-------'
-- --------
--------
-~---
-----------
----~-----------~
I am not really part of a team, but an individual like you who is seeking to make the world a safer and healthier place for
all. As I see the issues of TENO RM arise I have been pushing hard, rnaybe too hard from within my Division to encourage
us to address them, particularly as other states surrounding us are doing so. This all started with our correspondence in
past years where we were concerned that Kentucky would become a dumping ground for TENO RM if other states
prohibited the waste from being disposed in their states and we did not regulate TENORM within our state. We are at
that point.
What has been pointed out to me is that TE NORM is being disposed of in this state. We do not regulate disposal within
this state. The initiatives we are pursuing to restrict out of state waste is only reducing the business of companies like
Advanced TENO RM Services.
http://advtenorm.com/
I have heard indirectly that our Division Director is having someone look at the regulations and get familiar with
TENO RM but I am not part of that initiative, or at least not at this point.
At this point all I am to do is to talk or meet with individuals at landfills and look at their records or manifests to confirm
if TENO RM is being received. No meetings or monitoring at this time, only talking to others as coordinated by our field
officer personnel.
It also has been suggested by both the Solid Waste Branch and the Hazardous Waste Branch that we send "courtesy
letters" reminding our landfills and Advance. TEN ROM Services they are not to dispose of waste from out of state.
I do not feel we can do anymore at this time.
By the way from what I understand, Advanced TENO RM Services is only an address in a residential area in West Liberty
and all work is subcontracted out.
At this point, I will need to wait until I get instruction or direction from my management before I proceed further.
George

GP213
- l o George,
Mr. Chris Keffer from my office has volunteered to assist you at your inspection of Advanced TENORM Services in West
Liberty on Thursday. Chris will be bringing his rad survey meter set as well as a radioisotope identification device. Chris
worked in our lab for several years and he will also be bringing along supplies to take samples and bring them back to
the lab for radioanalytical analysis. Chris's contact information is as follows:
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
E-mail: Christopher.Keffer@ky.gov
A couple of things that my staff have brought to my attention regarding this matter that might interest you and your
colleagues in EEC. One is that we now have the ability to charge full cost reimbursement for our site investigations and
secondly, the Central Midwest Compact of which KY is a member with IL, specifically prohibits the import of NORM from
outside KY for disposal. From everything I have seen and heard, Advanced TE NORM Services in West Liberty is guilty of
violating this statute and subject to penalties and should be billed for our site visits. I will let you and Chris work out the
logistics of this site visit between yourselves.
~ards,
~t


211.869 Penalties. http://www.Irc.ky.gov/statutes/statute.aspx?id=850S

offense.
3
GP214
211.862 Definitions for KRS 211.861 to 211.869.

----~ --~~---(or-hy-past-human-practieesj~---~------~-- ------~----------~- ----------- ---- -~-~----- -------~----------~--- -- ---- --~----- --------- --

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
'~~
- ,,JI.;,.;;;.,

George, My staff and I would be happy to accompany you on your visit to Advanced TENO RM Services in West liberty,
to detect. We also have hand-held radioisotope identification devices (RllDs} that we can bring along to confirm the ID
gamma detectors whieh you are more than welcome to borrow. We can give you training on the meter sets as well. I am
unfortunately will not be able to join you on your trip to West liberty. However, I will see if I can 1 t get one of my staff to
accompany you or at least meet up with you at Advanced TENORM Services on Thursday. Looks like this might be the
impetus for finally getting us all moving on the TENORM front.
4
GP215
Mailstop HS1C-A
Frankfort, KY 40621
~ 502-564-3700 ext. 4183
~c 502-564-1492
Dispose of unwanted sources http:ijwww.crcpd.org/StateServices/SCATR.aspx
VsafU
...~
. .~.. ~
IW,f,}.-~:y
7~J!.ll!AT!ONM.H~J..TH

Hi Curt;
We are actively investigating the notice we received from Jason Frame (WV) that TENORM waste was disposed of here
.....West Liberty.
9':'dney Maze (field office) with our Division and I are working together on this.
I am not familiar with monitoring for TENO RM. Are there detectors (portable, hand held, etc.) that could be made
site. We also realize the landfills may be receiving in-state generated waste as well which is not regulated and has been
George

_ _ oMatt,
E ' k s like we have TE NORM contaminated hydraulic fracturing waste generated in WV being disposed of here at a
5
GP216

Irvine, KY 40336
Fax: 606-723-5607
General Manager
------ --:Emait~eharles:Laws@AtlvancedDisposal:com-- - ---Special Waste Expert: Billy Bowles
Phone: 606-975-7053
TENORM regs.
Thanks,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
L'enfufin-~
IV~J~'i.:W
r'. <1:r'J""'Jtr,1 ..~n:!:.r-U:..'iLf't
A.. '"'"". ill,,...,
i.ril<>lr;;f
"J,

Brine
6
GP217
A..
attatchment
I e!son R. Frame B.S. R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558~0524
m: Partrid. ge, George (EEC) [mailto:George.Partridge@ky.gov]

t: Friday, January 29, 2016 3:48 PM
Frame, Jason R
Jason;
TENORM disposal.

. . .ow some of the above items we discussed in our conversation but I was so floored with the news I want to be sure I
GP218
._.
George
(jeor9e P. PartrUJBe Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
GP219

Frame, Jason R
e!
Hello Mr. Frame,

TENORM Services of Liberty, KY (http:ljadvtenorm.com/ ). We will follow up with the company's president, Cory
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~your fees on line at https:ljprd.chfs.ky.gov/rad epay/
E~otified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
JQ.,.- --~
To:

Mr. Pendergrass,
I apologize for digging up this old email, but I don't believe I received any further response. I believe a company .

ce: (304)356-4303
(304) 558-0524
ail: Jason.R.Frame@WV.gov
GP220

To: Frame, Jason R

Hello Mr. Frame,
contaminated waste so Advanced TENORM Services might want to check with the authorities in those states to see what ~
is required.
A...
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
=-----------.-----~--~~~. ~-.- ~ - -. .-~~----~-.--"

10
GP221

TNORM disposal in KY
_;JJ/lject:
W.
Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
ain. confidenti.al information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
w, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
er by reply e-mail and destroy all copies of the original message.
11
GP222
elm:
Sent:
To:
Subject:
Attachments:

Maze, Rodney (EEC)
RE: General Information on Ra and TENORM
USGS Radium Report on GW.pdf; ANL-NDDH TENORM Landfill Study (ANL EVS-14_13)
Final Report.pdf
Rodney;
I included some additional general information on Ra and TENORM you might like to glance at:
USGS Summary of Ra-226 and Ra-228 in Shallow Ground Water in Southern New Jersey
Radiological Dose and Risk Assessment of Landfill Disposal of TENO RM by Argonne National Lab
Slide from EPA Presentation inserted below (in our case the generator is the landfill who sends the
contaminated leachate to a WWTP which then produces a sludge which is contaminated with radioactive
constituents).
---~
General Public
Workei
&posure
GP223
I am concerned about worker exposure as the waste is handled and spread. Also the contamination of the leachate
when the waste is co-mingled with municipal solid waste and the resulting pathways for exposure to receptors once the
contaminated leachate is treated at a wastewater treatment plant producing a sludge is another key point of concern.
I do feel TENO RM waste can be managed safely if we have a regulatory framework in place. Other states are moving
forward and we need to in Kentucky!
Thanks again for being so generous with your time considering how busy and demanding your schedule is to spend time
working with me on this issue that concerns me very much!
George
(jeorge P. Partrilfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP224
-m:
Sent:
To:
Subject:
Attachments:

Maze, Rodney (EEC)
RE: Qtr Reports for Selected Landfills and Company Info
Qtr WR - Company Info - TEN ORM Investigation - 020216.pdf
Rodney;
Please find attached the records I retrieved from TEMP0360
Quarterly Waste Received Reports for 2015:
Big Run
Green Valley
Blue Ridge
Morehead
Also have included:
Aerial View of Advanced TENO RM Services in West Liberty

List of Companies reported to be involved in shipment of TENO RM to Kentucky
f/lltview of Attachment
Big Run is only showing municipal waste from Marion Ohio. Green Valley appears to be site we need to focus on
regarding non-municipal waste from Ohio. Blue Ridge shows receiving non-municipal waste from Ohio for one quarter.
Big Run -1st & 2"d Qtrs, Marion County, WV

Blue Ridge - 3rd QTR from Muskingam County, Ohio
Green Valley- 2"d, 3rd, and 4th Qtrs from Muskingam County Ohio
I recommend that we focus visits on Advanced TENORM Services in West Liberty Kentucky and Green Valley Landfill to
get started with any investigations.
I care and I could not be more pleased to have the opportunity to make site visits and work with you. I apologize for the
tone of my email messages at times. I feel overwhelmed by all I have learned within the last two weeks and as I share
with others all the information I am receiving, I sense it is not a surprise or new information to them and this is an issue
that has been postponed being addressed by KOEP. I sense that this is something that everyone wants to move forward
carefully addressing considering the ultimate impact this may have as we learn more.
All I can think of is landfill operators are potentially be exposed to concentrated radioactive waste that is being comingled with municipal solid waste. The radioactive material can end up in the leachate based on the pH levels in the
landfill. If the landfill leachate is treated by a wastewater treatment plant, it can end up in the bio-solids which are then
disposed of. The long term effects are cancer to all who are exposed. An operator who is exposed today may not see .
effects for years or decades later and the link will never be established between the exposure and the cause of the
..A
~cer.
GP225
---------------------------
I also attached some additional information on Radium which is some of the key components in TENO RM if you would
like to look at it.
I want to be respectful of management and at the same address the urgency of this situation since this involves human
health and the well-being of those we serve.
Thank you again for all you do and how hard you work for our Division.
George
{]eorge P. PartrUfee Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP226
t/lm:
Sent:
To:
Subject:
Attachments:

FW: RE: General Information on Ra and TENORM
USGS Radium Report on GW.pdf; ANL-NDDH TENORM Landfill Study (ANL EVS-14_13)
Final Report.pdf
Lindsey;
Info I shared with Rodney.
George

Subject: RE: General Information on Ra and TENORM
Rodney;
I included some additional general information on Ra and TENORM you might like to glance at:
flt
USGS Summary of Ra-226 and Ra-228 in Shallow Ground Water in Southern New Jersey
Radiological Dose and Risk Assessment of Landfill Disposal of TENO RM by Argonne National Lab
Slide from EPA Presentation inserted below (in our case the generator is the landfill who sends the
contaminated leachate to a WWTP which then produces a sludge which is contaminated with radioactive
constituents).
GP227
---~
Worker
General Pu,bllc
Exposure
I am concerned about worker exposure as the waste is handled and spread. Also the contamination of the leachate
when the waste is co-mingled with municipal solid waste and the resulting pathways for exposure to receptors once the
contaminated leachate is treated at a wastewater treatment plant producing a sludge is another key point of concern.
I do feel TENO RM waste can be managed safely if we have a regulatory framework in place. Other states are moving
forward and we need to in Kentucky!
Thanks again for being so generous with your time considering how busy and demanding your schedule is to spend time
working with me on this issue that concerns me very much!
George
<;ieorge P. Partritfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP228
GP229
-m:

Maze, Rodney (EEC)
Re: Qtr Reports for Selected Landfills and Company Info
imageOOl.gif
Sent:
To:
Subject:
Attachments:
George,
I know the area where the Advanced Te norm Services is located in West Liberty. I didn't know it existed until now. How
about meeting at the Grayson rest area about 9:00 am Thursday morning? Thanks for the assistance.
Rodhey
Rodney Maze

Rodney;
Big Run
Green Valley
Blue Ridge
Morehead
Also have included:
Aerial View of Advanced TENORM Services in West Liberty

Review of Attachment
Big Run is only showing municipal waste from Marion Ohio. Green Valley appears to be site we need to
focus on regarding non-municipal waste from Ohio. Blue Ridge shows receiving non-municipal waste
from Ohio for one quarter.

I recommend that we focus visits on Advanced TENO RM Services in West Liberty Kentucky and Green
Valley Landfill to get started with any investigations.
I care and I could not be more pleased to have the opportunity to make site visits and work with you.
apologize for the tone of my email messages at times. I feel overwhelmed by all I have learned within
the last two weeks and as I share with others all the information I am receiving, I sense it is not a
1
GP230
surprise or new information to them and this is an issue that has been postponed being addressed by
KOEP. I sense that this is something that everyone wants to move forward carefully addressing
considering the ultimate impact this may have as we learn more.
All I can think of is landfill operators are potentially be exposed to concentrated radioactive waste that is
being co-mingled with municipal solid waste. The radioactive material can end up in the leachate based
on the pH levels in the landfill. If the landfill leachate is treated by a wastewater treatment plant, it can
end up in the bio-solids which are then disposed of. The long term effects are cancer to all who are
exposed. An operator who is exposed today may not see the effects for years or decades later and the
-~~---------~-link_wilLne~eche_estahlisbe_d_b_e_twe_entbe.e_xr:10--5ure and_tb_~_cause Qf th_e_canc!'!r. _____ ~~-------- __ ~-~------- ________ _
I also attached some additional information on Radium which is some of the key components in
TENO RM if you would like to look at it.
I want to be respectful of management and at the same address the urgency of this situation since this
involves human health and the well-being of those we serve.
George
<jeorge P. Partridjje Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
<Qtr WR- Company Info - TENORM Investigation - 020216.pdf>
GP231
#m:
Sent:
To:
Subject:

Wednesday, February 03, 2016 7:47 AM
RE: Visit to Advanced TENORM Services
Good Morning Chris!

Curt mentioned you would be visiting Advanced TENORM Services on Thursday. I am also scheduled to visit Landfills
(Greenup, Big Run, etc.) and Advanced TE NORM Services on Thursday as well with Rodney Maze, an inspector with the
Division of Waste Management. I would like very much for us to meet you there.
Let's set up a time to meet in West Liberty on Thursday and then I hope to arrange my schedule around that time with
Rodney.
I thought we could meet at McDonald's on 1640 W. Main St. in West Liberty, KY and then head to the company
together.
Let's exchange cell numbers so we can keep in touch. Mine is 859-221-8843.
Please email me or call me as soon as convenient this morning so we can plan for tomorrow.
,predate all you and Curt are doing to address TENORM issues here in Kentucky.
Thank you,
George
(jeorge P. Partricfae Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP232
Subject:

RE: RE: Visit to Advanced TENORM Services
George,
I Have been asked to look into a concern regarding Advanced TENO RM Services and I do intend to be at the site
on Thursday. However I do not have a time frame in mind as of yet. Is there a time that would suit you and your
colleague so that the site visit did not interfere with other plans you have for that day already? If you think it would be
prudent I can accompany you to the other sites if it is suspected that radioactive material, TENO RM in this case would be
present.
My contact information is below however the cell phone that I carry is (502) 330-2886.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
TICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
ain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
Sent:

To: Keffer, Christopher (CHFS Rad Hlth)
Subject: RE: Visit to Advanced TENORM Services
Good Morning Chris!
Curt mentioned you would be visiting Advanced TENORM Services on Thursday. I am also scheduled to Visit Landfills
(Greenup, Big Run, etc.) and Advanced TE NORM Services on Thursday as well with Rodney Maze, an inspector with the
Rodney.
I thought we could meet at McDonald's on 1640 W. Main St. in West Liberty, KY and then head to the company
together.
Let's exchange cell numbers so we can keep in touch. Mine is 859-221-8843 .
se email me or call me as soon as convenient this morning so we can plan for tomorrow .
appreciate all you and Curt are doing to address TENORM issues here in Kentucky.

1
GP233
Thank you,
George

____ r_anktort,_KY_A.D_6_0L~~-~-~-__________ ---~------~~------------------------------------~----~~---- ______ _______----~--------~--~---~-~------- _
(502) 564-6716 ext. 4651
GP234

. .m:
Sent:
To:
Cc:
Subject:

RE: RE: Visit to Advanced TE NORM Services
Chris;
Thank you for getting back with me so quickly. I have called Rodney Maze and should hear from him shortly. My goal is
to meet you at Advanced TENORM Services for a site visit. The balance of the day Rodney and I plan to visit landfills we
have reason to believe may be receiving TENO RM waste from out of state. Our management at this point just wants us
to limit our visits to talking with operating personnel and review their manifests and waste receipt records to hopefully
identify or confirm that they have received TENO RM. If we confirm that TENO RM has been received at the site, we
should also know both if solidification of the waste took place before it was landfilled as well as having a record of the
specific cell or area of the landfill the wastes was deposited in. With that information in hand the next step would be to
check for the level of contamination and radioactivity.
Since Rodney and I will just be reviewing files at the landfills at this point (they are required to keep records for 3 years
available for inspection), I feel it would be of limited benefit for your group to accompany us at this time to the
landfills. Once we confirm waste disposal and know the locations to check, that is when it would be an excellent
opportunity to conduct a site survey and scan for radioactivity/TENORM.
f/l,o, our Assistant Director Jon Maybriar (who is also acting supervisor of the fields operation branch), requested
yesterday that we do not get your department or section involved in the investigation and that at this time we only
meet with individuals at the site, review files, and ask about their detection equipment for radioactivity when the truck
are received in the scale area.
Look forward to following up with you shortly.
Thank you,
George
Sent: Wednesday, February 03, 2016 8:13 AM

Subject: RE: RE: Visit to Advanced TENORM Services

George,
I Have been asked to look into a concern regarding Advanced TENO RM Services and I do intend to be at the site
on Thursday. However I do not have a time frame in mind as of yet. Is there a time that would suit you and your
colleague so that the site visit did not interfere with other plans you have for that day already? If you think it would be
prudent I can accompany you to the other sites if it is suspected that radioactive material, TENO RM in this case would be
present.
My contact information is below however the cell phone that I carry is (502) 330-2886.
I
1
GP235

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
..
0 -~--Er_om:J!artridge,~George_GEEC)_~----________~------- _____________________-------------------~----- ---~--~ -~~~---~--~~~----- __ ~----

Subject: RE: Visit to Advanced TENORM Services
Good Morning Chris!
Curt mentioned you would be visiting Advanced TENORM Services on Thursday. I am also scheduled to visit Landfills
(Greenup, Big Run, etc.) and Advanced TENORM Services on Thursday as well with Rodney Maze, an inspector with the
Rodney.
I thought we could meet at McDonald's on 1640 W. Main St. in West Liberty~ KY and then head to the company
together.
Let's exchange cell numbers so we can keep in touch. Mine is 859-221-8843.
Please email me or call me as soon as convenient this morning so we can plan for tomorrow.
I appreciate all you and Curt are doing to address TENORM issues here in Kentucky.
Thank you,
George
(ieorge P. PartrUge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP236
t/!m:
Sent:
To:
Subject:

Wednesday, February 03, 2016 12:38 PM
RE: Meeting at Advanced TENO RM Services
Chris:
Rodney Maze (DWM Morehead Regional Field Office Inspector) and I would like to join you for the visit to Advanced
TENORM Services. Rodney starts his day at the Morehead Office at 8 AM. I live in Nicholasville and will be leaving from
Frankfort.
Would meeting at the field office at 8 AM or shortly afterwards work for you? That way we could meet with Rodney and
then the three of us head down to West Liberty.
My understanding is you would be bringing your rad survey meter set as well as a radioisotope identification device,
along with supplies to take samples and bring them back to the lab for radioanalytical analysis.
Ideally the visit would help us confirm if the company is working with TENO RM as well as finding out if they are receiving
it from out of state.
The Morehead Field Office is right off the exit behind Cracker Barrel. The address is:
-
Hecks Plaza Dr.

Morehead, KY 40351
After our visit to West Liberty, Rodney and I will be visiting some landfill sites to review manifests that document wastes
received and talking to operating personnel to investigate if they are receiving TENO RM or are aware of the situation.
We will need to take separate vehicles and meet in Morehead.
Let me know your thoughts on the time you would like to meet there.
Thank you,
George
(jeorge P. Partridjje Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP237
-m:

Maze, Rodney (EEC)
Re: Qtr Reports for Selected Landfills and Company Info
imageOOl.gif
Sent:
To:
Subject:
Attachments:
It's a go for tomorrow. What time will the Rad Branch and yourself meet me at the Morehead Regional Office in the
morning.
Thanks
Rodney
Rodney Maze
On Feb 2, 2016, at 7:53 PM, Maze, Rodney (EEC) <Rodney.Maze@ky.gov> wrote:

George,
I know the area where the Advanced Tenorm Services is located in West Liberty. I didn't know it existed
until now. How about meeting at the Grayson rest area about 9:00 am Thursday morning? Thanks for
the assistance.
Rodney
Rodney Maze

Rodney;
Big Run
Green Valley
Blue Ridge
Morehead
Also have included:

List of Companies reported to be involved in shipment of TE NORM to Kentucky
Big Run is only showing municipal waste from Marion Ohio. Green Valley appears to be
site we need to focus on regarding non-municipal waste from Ohio. Blue Ridge shows
receiving non-municipal waste from Ohio for one quarter.
1
GP238
Big Run -1st & 2nd Qtrs, Marion County, WV

Green Valley- 2nd, 3rd, and 4th Qtrs from Muskingam County Ohio
I recommend that we focus visits on Advanced TENORM Services in West Liberty

Kentucky and Green Valley Landfill to get started with any investigations.
I care and I could not be more pleased to have the opportunity to make site visits and
------ --- -. ---- , ---- ------ .. ---- ---wo.r:kwitb-v-o-LI-.-o''--1.a po lo.g.i ze,JoJ_the_to n.e._of_m\cem aJLme_ss_ag_e s__at_ti_m_e,s_. __ J_fe_eJ___~----._____ ____ .__________________
overwhelmed by all I have learned within the last two weeks and as I share with others
all the information I am receiving, I sense it is not a surprise or new information to them
and this is an issue that has been postponed being addressed by KOEP. I sense that this
is something that everyone wants to move forward carefully addressing considering the
ultimate impact this may have as we learn more.
All I can think of is landfill operators are potentially be exposed to concentrated
radioactive waste that is being co-mingled with municipal solid waste. The radioactive
material can end up in the leachate based on the pH levels in the landfill. If the landfill
leachate is treated by a wastewater treatment plant, it can end up in the bio-solids
which are then disposed of. The long term effects are cancer to all who are
exposed. An operator who is exposed today may not see the effects for years or
decades later and the link will never be established between the exposure and the cause
of the cancer.
I also attached some additional information on Radium which is some of the key
components in TENO RM if you would like to look at it.
I want to be respectful of management and at the same address the urgency of this
situation since this involves human health and the well-being of those we serve.
George
~eorgeP.PartrUJBeJ~
Frankfort, KY 40601
(502) 564-6716 ext. 4651
<imageOOl.gif>
<Qtr WR- Company Info -TENORM Investigation - 020216.pdf>

<imageOO 1. gif>
GP239
-.-o., _
,_._~
-m:

Maze, Rodney (EEC)
RE: Qtr Reports for Selected Landfills and Company Info
Sent:
To:
Subject:
Rodney;
Great! I will give Chris a call and send both an email message and a text message confirming our visit to West Liberty
and the time we will be at your office in Morehead.
Thank you!
George
Sent: Wednesday, February 03, 2016 3:27 PM

Subject: Re: Qtr Reports for Selected Landfills and Company Info
morning.
-~~~
Rodney Maze

George,
I know the area where the Advanced Teno rm Services is located in West Liberty. I didn'.t know it existed
the assistance.
Rodney
Rodney Maze

Rodney;
Big Run
Green Valley
Blue Ridge
1
GP240
Morehead
Also have included:

list of Companies reported to be involved in shipment of TENO RM to Kentucky
--~---------- ----~-:i~~~:-~~~~l~~s~:c:~~~~~;:~~i~l~~~~~~~n~cl~:t~~;~b:~~:-~~!,y-:~-~:c~-::a;~!~~~~-----~--~~--C~ - -- ------receiving non-municipal waste from Ohio for one quarter.
Big Run - 1st & 2"d Qtrs, Marion County, WV

I recommend that we focus visits on Advanced TENO RM Services in West Liberty

work with you. I apologize for the tone of my email messages at times. I feel
overwhelmed by all I have learned within the last two weeks and as I share with others
and this is an issue that has been postponed being addressed by KDEP. I sense that this
of the cancer.
George
(;eorge P. PartridfJe Jr.

Frankfort, KY 40601
2
GP241
(502) 564-6716 ext. 4651

<image001.gif>

<imageOO 1. gif>
GP242
-m:
Subject:

Maze, Rodney (EEC)
RE: Site Visit to Advanced TENORM Servicies in West Liberty
Tracking:
Recipient
Delivery
Read
Maze, Rodney (EEC)
Delivered: 2/3/2016 4:42 PM
Read: 2/3/2016 5:43 PM
Sent:
To:
Rodney;
Chris and I plan to meet you at your office in Morehead at 8 am or as soon as possible after that time (cannot get a
vehicle until 6:45 AM in the morning, tried this afternoon, but my original pickup time was 7 am tomorrow and no other
vehicles were available to get this afternoon.)
Chris will be bringing his screening and detection equipment along with his sampling equipment. He plans to do a very
thorough investigation of the facility.
Look forward to seeing you in the morning!
George
fl/>ris's contact information is below
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

morning.
Thanks
Rodney
Rodney Maze
~eb
2, 2016, at 7:53 PM, Maze, Rodney (EEC) <Rodney.Maze@ky.gov> wrote:

George,
1
GP243
I know the area where the Advanced Tenorm Services is located in West Liberty. I didn't know it existed
the assistance.
Rodney
Rodney Maze

Rodney;
Big Run
Green Valley
Blue Ridge
Morehead
Also have included:
Aerial View of Advanced TENORM Services in West Liberty

Big Run is only showing municipal waste from Marion Ohio. Green Valley appears to be
site we need to focus on regarding non-municipal waste from Ohio. Blue Ridge shows
receiving non-municipal waste from Ohio for one quarter.

I recommend that we focus visits on Advanced TENO RM Services in West Liberty

work with you. I apologize for the tone of my email messages at times. I feel
overwhelmed by all I .have learned within the last two weeks and as I share with others
and this is an issue that has been postponed being addressed by KOEP. I sense that this
2
GP244
of the cancer.
George
<;jeorge P. Partricfae Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
<imageOOl.gif>

<imageOO 1. gif>
'"'
L_
GP245
-m:
Sent:
To:
Subject:
Kaiser, Samantha (EEC)

Laboratory Certification for Advanced Tenorm Services
Hi George,
I believe you left me a voicemail on Friday Jan 29 concerning a laboratory Advanced Tenorm. I tried to return your call
and left you a voicemail. If you still need my assistance with anything, please let me know when a good time is.
Thank you
Samantha Kaiser
Environmental Scientist II
Division of Water
Laboratory Certification Program
200 Fair Oaks 4th Floor
Frankfort, Kentucky 40601
(502) 564-3410 ext. 4815
(502) 564-0111 Fax
..
1
GP246
-m:
Sent:
To:
Subject:
Attachments:

Advanced TENORM Services
KY08061 WW Method Analyte List 2015 Rl.xlsx
Samantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
(502) 564-0111 Fax
..
1
GP247
e!~=
To:
Cc:
Subject:
Attachments:

Maze, Rodney (EEC)
FW: Advanced TENORM Services
KY08061 WW Method Analyte List 2015 Rl.xlsx
Rodney;
Samantha with the DOW sent me the attachment. The DOW has Advanced TENORM Services as a certified lab for pH,
O&G, and TSS. That is all they are permitted or certified for with the DOW.
See you in the morning!
George
From: Kaiser, Samantha (EEC)

Subject: Advanced TENORM Services
tl!.mantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
(502) 564-0111 Fax
GP248
tlom:
Sent:
To:
Subject:
Maze, Rodney (EEC)

Re: Site Visit to Advanced TENORM Servicies in West Liberty
Looks like a learning day for me

Rodney Maze

Rodney;
Chris and I plan to meet you at your office in Morehead at 8 am or as soon as possible after that time
(cannot get a vehicle until 6:45 AM in the morning, tried this afternoon, but my original pickup time was
7 am tomorrow and no other vehicles were available to get this afternoon.)
Chris will be bringing his screening and detection equipment along with his sampling equipment. He
plans to do a very thorough investigation of the facility.
George
(Chris's contact information is below
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

It's a go for tomorrow. What time will the Rad Branch and yourself meet me at the Morehead Regional
Office in the morning.
Thanks
Rodney
Rodney Maze
GP249

George,
I know the area where the Advanced Te norm Services is located in West Liberty. I didn't
know it existed until now. How about meeting at the Grayson rest area about 9:00 am
Thursday morning? Thanks for the assistance.
Rodney
~-~~---- __________________ BJ:>_dne')' M_az_e__ _-----------------~-- -------------------~-________ _

Rodney;
Big Run
Green Valley
Blue Ridge
Morehead
Also have included:

List of Companies reported to be involved in shipment of
TENORM to Kentucky
Big Run is only showing municipal waste from Marion Ohio. Green
Valley appears to be site we need to focus on regarding non-municipal
waste from Ohio. Blue Ridge shows receiving non-municipal waste from
Ohio for one quarter.
Big Run - l 5t & 2nd Qtrs, Marion County, WV

Green Valley- 2nd, 3rd, and 4th Qtrs from Muskingam County
Ohio
I recommend that we focus visits on Advanced TENO RM Services in

West Liberty Kentucky and Green Valley Landfill to get started with any
investigations.
I care and I could not be more pleased to have the opportunity to make
site visits and work with you. I apologize for the tone of my email
messages at times. I feel overwhelmed by all I have learned within the
last two weeks and as I share with others all the information I am
receiving, I sense it is not a surprise or new information to them and this
is an issue that has been postponed being addressed by KOEP. I sense
2
GP250
that this is something that everyone wants to move forward carefully

addressing considering the ultimate impact this may have as we learn
more.
All I can think of is landfill operators are potentially be exposed to
concentrated radioactive waste that is being co-mingled with municipal
solid waste. The radioactive material can end up in the leachate based
on the pH levels in the landfill. If the landfill leachate is treated by a
wastewater treatment plant, it can end up in the bio-solids which are
then disposed of. The long term effects are cancer to all who are
exposed. An operator who is exposed today may not see the effects for
years or decades later and the link will never be established between
the exposure and the cause of the cancer.
I also attached some additional information on Radium which is some of
the key components in TENO RM if you would like to look at it.
I want to be respectful of management and at the same address the
urgency of this situation since this involves human health and the wellbeing of those we serve.
George
{]eorge P. Partridfie Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
<image001.gif>

<imageOO 1. gif>
GP251
It/lam,
Sent:
To:
Subject:

Thursday, February 04, 2016 6:18 AM
Maze, Rodney (EEC)
RE: Site Visit to Advanced TENORM Servicies in West Liberty
Rodney;
For me to too! I am really looking forward to today and feel after three years of following the disposal issues related to
TENORM we are finally addressing it in Kentucky!
Thanks again for all you are doing to support this effort!
See you shortly!
George

Subject: Re: Site Visit to Advanced TENORM Servicies in West Liberty

- k s like a learning day for me
Rodney Maze

Rodney;
Chris and I plan to meet you at your office in Morehead at 8 am or as soon as possible after that time
(cannot get a vehicle until 6:45 AM in the morning, tried this afternoon, but my original pickup time was
7 am tomorrow and no other vehicles were available to get this afternoon.)
Chris will be bringing his screening and detection equipment along with his sampling equipment. He
plans to do a very thorough investigation of the facility.
George
{Chris's contact information is below
Frankfort, KY 40601
Ph: 502-564-3700 x4179
1
GP252
Cell: 502 330-7662

FAX: 502-564-1492

It's a go for tomorrow. What time will the Rad Branch and yourself meet me at the Morehead Regional
~--=-----------'--
Qffj(e in the
--- --- -- ---------------..-------- ____., , _______
morning.---~----------------------------------------
~ ~--~--~-----=--=--~---~-~--~----
--
Than ks
Rodney
Rodney Maze

George,
I know the area where the Advanced Tenorm Services is located in West Liberty. I didn't
know it existed until now. How about meeting at the Grayson rest area about 9:00 am
Thursday morning? Thanks for the assistance.
Rodney
Rodney Maze

Rodney;
Big Run
Green Valley
Blue Ridge
Morehead
Also have included:

List of Companies reported to be involved in shipment of
TENORM to Kentucky
Big Run is only showing municipal waste from Marion Ohio. Green
Valley appears to be site we need to focus on regarding non-municipal
waste from Ohio. Blue Ridge shows receiving non-municipal waste from
Ohio for one quarter.
2
GP253
Big Run -1st & 2nd Qtrs, Marion County, WV

Green Valley- 2nd, 3rd, and 4th Qtrs from Muskingam County
Ohio
I recommend that we focus visits on Advanced TE NORM Services in

West Liberty Kentucky and Green Valley Landfill to get started with any
investigations.
I care and I could not be more pleased to have the opportunity to make
site visits and work with you. I apologize for the tone of my email
messages at times. I feel overwhelmed by all I have learned within the
last two weeks and as I share with others all the information I am
receiving, I sense it is not a surprise or new information to them and this
is an issue that has been postponed being addressed by KOEP. I sense
that this is something that everyone wants to move forward carefully
addressing considering the ultimate impact this may have as we learn
more.
All I can think of is landfill operators are potentially be exposed to
concentrated radioactive waste that is being co-mingled with municipal
solid waste. The radioactive material can end up in the leachate based
on the pH levels in the landfill. If the landfill leachate is treated by a
wastewater treatment plant, it can end up in the bio-solids which are
then disposed of. The long term effects are cancer to all who are
exposed. An operator who is exposed today may not see the effects for
years or decades later and the link will never be established between
the exposure and the cause of the cancer.
I also attached some additional information on Radium which is some of
the key components in TENO RM if you would like to look at it.
I want to be respectful of management and at the same address the
urgency of this situation since this involves human health and the wellbeing of those we serve.
George
<george P. Partricfee Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
"
<imageOOl.gif>

<imageOO 1. gif>
3
GP254
i'-m:
Sent:
To:
Cc:
Subject:
Attachments:
Tracking:

Thursday, February 04, 2016 10:10 PM
Maze, Rodney (EEC); Briggs, Lindsey (EEC)
RE: Advanced TENORM Services
Advanced TENORM Services - Photos - 020416.pdf; Advanced TENORM Services.pdf;
BES LLC.pdf; BES Technical Solutions.pdf; Bluegrass Environmental Services.pdf;
Organizers of LLCs.pdf
Recipient
Delivery
Delivered: 2/4/2016 10:10 PM
Maze, Rodney (EEC)
Delivered: 2/4/2016 10:10 PM
Delivered: 2/4/2016 10:10 PM
Chris;
As we discussed Thursday evening, I searched the Internet to locate both the web site for Advanced TENORM Services as
well as any business activities of Cory Hoskins or family members. It appears they have been involved in numerous LLC
formation activities in recent years Please find the documents I located related to that search. I have also included the
photos I took from the site visit which shows the Kentucky Office of Advanced TENORM Services.
- o k forward to us keeping in touch and continuing our investigation.
Thank you,
George
(jeorge P. Partritfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP255
1-m:
Sent:
To:
Subject:

Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney (EEC)
Chris and Rodney;

As I recall Cory gave the impression that the web site was something he didn't keep up with , it was created awhile back
and he no longer worked or was actively involved with the listed "Vice President - Dr. Leong Ying." He also said Dr. Ying
was not a member of the corporation.
Please note that the Website is marked "Copyright 2016 - design 53".
Seeing the 2016 date gives me the impression it was recently updated?
So much I am trying to sort out regarding what Cory told us.
Look forward to us keeping in touch.
Thanks again for all you both are doing!
-orge
<jeorge P. Partrid:ge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
I..
GP256
-om:
Sent:
To:
Cc:
Subject:

Friday, February 05, 2016 9:45 AM
Pendergrass, Curt (CHFS DPH); McKinley, Matthew W {CHS-PH)
Advanced TENORM Services
George,
I wanted to let you know that I have received your emails and to see if you would be available for a meeting
Tuesday, Wednesday or Thursday next week in order to discuss our findings and possible actions that will be taken.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
"
1
GP257
f/Am:
Sent:
To:
Cc:
Subject:
Attachments:

Frame, Jason R
Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)
Hello Jason,
I have huge favor to ask of you. Is there any way that you can contact Fairmont Brine Processing in Fairmont WV and ask
them for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I would
presume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
number was the radioanalytical analysis of this wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on
contact with the waste containers.
sludge. The West Virginia Department of Environmental Protectio

processed FBP's Notification of Regulated Waste Activity Form. A!
Environmen"t"I Protection Agency (US EPA) Identification Number
~o, I remember seeing something in the lay press about WV issuing new regulations regarding TENOR.M. However, I
9'fi't seem to find anything on the web other this blurb below which references 185 Bq/kg or 5 pCi/g above natural
background. I am assuming FBP analyzed the loads in question and determined they exceeded this WV limit. Also, I am
assuming this limit is based on protecting public and health and safety of the citizens of WV but what I saw seemed to be
more of a proposed rule and not an actual regulation
(http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping thatyou can share copy or a
link to the actual WV regulation which references this TE NORM limit for disposal in WV. I believe OH chose to use this 5
pCi/g Ra-226 + Ra-228 plus daughter products as well as their limit for disposal in the regular waste stream.
Just to let you know, while KY lacks specific regs addressing TE NORM, our Central Midwest Interstate Low-Level Waste
Compact of which KY is a member along with IL, specifically prohibits the disposal of out-of-compact wastes here in KY.
~below. How that tie.sin with the E. PA's determination that "Wastes generated during the explor.atio.n, development,
~production of crude oil, natural gas, and geothermal energy are categorized by EPA as "special wastes" and are
exempt from federal hazardous waste regulations under Subtitle C of the Resource Conservation and Recovery Act
(RCRA)" will be question for my colleagues in the Energy and Environment Cabinet to answer. But if you actual
radioanalytic data on these loads from FBP that you could share with us, we would be extremely grateful.
1
GP258
Thanks,
Curt

~hall b~}!ie exclysiye re~ul~tory r~spon.sibility .?f the states,~xQe~f1i~t;9 p~t~o~
--------
-~----
~--

( 1) Any person who fails to comply with any provision of KRS 211.859 or 211.863, or
offense.
practices, Naturally occurring radioactive material does not include the natural
radioacti'1ity ?r,rocks or soils, o~~ackgrm1nd radiation, but instea~(~f~]:'s;{~
~ff~l~"," :''~~
7
:"a~:. ~si;~;J~!!11qtggi~~r!&~fth~ii'~~~~~t.'Enff2i!~11l~~f~~ls~s

Supervisor, Radioactive Materialssection
Mailstop HSiC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564~1492
Website: http://www.thfs.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:LLsecure.kentucky.gov{RegwatchL
Dispose of unwanted sources http:ljwww.crcpd.org{StateServices{SCATR.aspx
';~--
M
2
GP259

~ Partridge, George (EEC)
~Pendergrass, Curt (CHFS
DPH)
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
I be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding
ORM disposal.
..
3
GP260

,
I ~--~--~!!___J\Jam_e_oLcomp_ito)' in_Eairm__QD! along with Co!.!!1__!y1-llii1__QDtra__c:ted 'lfl!J!h Advaoced UNQBM Services,--~~--~-~
George
(jeorge P. PartridiJe Jr., PfiV, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
4
GP261
Fax: (304) 558-0524


To: Frame, Jason R
Hello Mr. Frame,
~nk you for the follow-up e-mail on the purported disposition of WV TENO RM wastes here in KY by Advanced
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
.Jt;l.\T~Qff,.<1,p,,, il'\1c~""L 1i1"1
;;;;,;;;;;:;,;;;;;;,
R [ mallto :Jason.R.Frame@wv.gov]
J-;;~n
GP262

Mr. Pendergrass,
I
--
--
-~-----~--~--~----------~--- ----~---~----------~----~~-~- -------- ----
- - - - - - - - -- - - - - - - - - - - - - - -------~~----- ~------ - - - ---~~~---- - -

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
is required.
.....
Regards,
GP263
Curt Pendergrass1 Ph.D.

Supervisor1 Radioactive Materials Section
iation Health Branch
East Main Street
!stop HS1C-A
Frankfort1 KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
.l
Act1 18 U.S.C. Sections 2510-2521. Its intended to be delivered only to the named
intended recipient 1 be advised that you have received this e-mail in error and
that any use1 dissemination 1 forwarding 1 printing 1 or copying of this e-mail is
prohibited. If you have received this e-mail in error1 please notify the sender
communication, either written or implied 1 constitutes or should be construed as a
herein.
Sent: Tuesday1 July 21, 2015 1:19 PM

,..A Pendergrass,
....
999 ). From Mr. Frames understar)ding, Advanced TENORM Services L.L.C. (located in West Liberty, KY) will be solidifying
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you ate notified that any
r by reply e-mail and destroy all cop1es of the original message.
GP264

RE: RE: Advanced TENORM Services
Subject:
According to the company's filings with the KY Secretary of State, Cory Hawkins is the managing member of Advanced
TENORM Services LLC and his wife is the organizer (https://app.sos.ky.gov/corpscans/60/0904260-06-99999-20150819ARA-6281199-PU.pdf and https://app.sos.ky.gov/corpscans/60/0904260-06-99999-20141208-AOG-6004652-PU.PDF ).
Tax returns are confidential information but I know I could get the KY Dept. of Revenue to let us know if the company
would qualify as a Certified Small Business Entity based on their average gross receipts forthe last three years based on
less $485,000 or less than $7 million (http://www.chfs.ky.gov/NR/rdonlyres/6DOFA82A-EBA8-47CB-9C3D6A1C872F1921/0/RPS526 Small BusinessEntity Certification1212014.pdf) should we make them apply for a license.
Maybe good information to have should we pursue legal action against the company to remove the wastes disposed of
here in KY and dispose of it a properly permitted landfill in another state.
Mailstop HSlC-A
Frankfort, KY 40621
502-564-3700 ext. 4183
~: 502-564-1492
Website: http://www.chfs.ky .govId ph/rad ioa ctive .htm
,.A:
~rJli.
IV...,
Sent: Friday, February 05, 2016 9:28 AM

To: Pendergrass, Curt (CHFS DPH); McKinley, Matthew W (CHS-PH)
Subject: FW: RE: Advanced TENORM Services

Sent: Thursday, February 04, 2016 10:17 PM

To: Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney (EEC)
Subject: RE: Advanced TENORM Services
Chris and Rodney;
As I recall Cory gave the impression that the web site was something he didn't keep up with , it was created awhile back
no longer worked or was actively involved with the listed "Vice President - Dr. Leong Ying." He also said Dr. Ying
WJwas not a member of the corporation.
a9he
1
GP265
So much I am trying to sort out regarding what Cory told us.
_______G.emge___~--_____.__ ____.-----~--------~----------- -----~--------------- ___ _
(jeorge P. Partricfae Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP266
-m:
Sent:
To:
Subject:
Hendricks, Todd (EEC)

Friday, February OS, 2016 10:15 AM
FW: TENORM Environmental Monitoring
FYI
From: Hendricks, Todd (EEC)

To: Aldridge:, Louanna (EEC)
Cc: Anderson, Danny J (EEC); Briggs, Lindsey (EEC)
Subject: TENORM Environmental Monitoring

Louanna,
The parameters we need to be concerned with are:
Radium-226
Radium-228
Polonium-210
Lead-210
forms from the decay of radium; preferentially follows other gases, can end up in landfill gas, prefers ethane
~ propane. Will eventually end up being released through the landfill or gas system into the air,
Uranium and Thorium are present, normally at lower quantities than Radium.
,..M_on -
All pathways for environmental releases should be monitored. The pathways for release are groundwater, surface
water, air, and leachate.
Groundwater: A landfill that has accepted TENORM should already have a functioning groundwater monitoring system
approved by the cabinet. The landfill should be required to monitor groundwater quarterly for Radium-226, Radium228, Polonium-210, Lead-210, and Radon. Although Radon is a gas, it should partition into the water or leachate.
Surface water: The landfill should already have a functioning surface water monitoring system. Surface water should be
monitored at least as often as the groundwater (i.e., quarterly) for the same list of parameters. Radon will probably not
be an issue.
Leachate: Leachate is a significant potential pathway for release. In particular, if leachate is sent to a wastewater
treatment plant, the radionuclides could end up affecting workers at the WWTP, being discharged to surface water
through poorly-monitored outfalls. It could also be retained in WWTP sludge and possibly land applied or distributed to
the public. The landfill should be required to monitor leachate at least quarterly (preferably each time it leaves the site)
for Radium-226, Radium-228, Polonium-210, Lead-210, and Radon.
Air: Landfill gas could contain Radon; some will be released directly from the landfill into the air through cover or the
working face. If the gas is passively vented, flared, or used to generate electricity, air releases will occur through those
ways.
If you have any other questions, please feel free to ask.
GP267
Regards,
Todd
Todd Hendricks, P.G.

Geologist
Kentucky Division of Waste Management
Solid Waste Branch
200 Fair Oaks Lane
~-~----Fr-aAkfort,K-Y-40601----------~----------
--------- --------------- ----
502-564-6716 ext. 4653
GP268
To:
Cc:
Subject:

WV DEP is not involved in any type of radiological permitting. I believe you are referring to the drill cuttings disposal regs
that we developed with WVDEP which set gate alarms of 2x background and then 5 pCi/g radium 226/228 above local
background analytical limits. I may already have data for the loads. Will check.

Office: (304)356~4303
Fax: (304) 558~0524

To: Frame, Jason R
Cc: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)

Hello Jason,
them for actual data on these loads as to the activity co.ncentration of Ra-226 + Ra-22.8 plus daughter products? I would
GP269

processed FBP's Notiflcation of Regulated Waste Activity Form. A.
Environmental Protection Agency (US EPA) Identification Number
Also, I remember seeing something in the lay press about WV issuing new regulations regarding TENO RM. However, I
can't seem to find anything on the web other this blurb below which references 185 Bq/kg or 5 pCi/g above natural
~~--b-aek-grnund~l-am-assum~n~FBP-analy-zed-tl-1e-loads-in-que--sti9n-and-de-ter:m ined-the-v-exceeded~tbis-W_V_limiLAlso,ia m~----~
assu ming this limit is based on protecting public and health and safety of the citizens of WV but what I saw seemed to be
(http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping that you can share copy or a
link to the actual WV regulation which references this TENORM limit for disposal in WV. I believe OH chose to use this 5
Just to let you know, while KY lacks specific regs addressing TENORM, our Central Midwest Interstate Low-LevelWaste
Compact of which KY is a member along with IL, specifically prohibits the disposal of out-of-compact wastes here, in KY.
See below. How that ties in with the EPA's determination that "Wastes generated during the exploration, development,
and production of crude oil, natural gas, and geothermal energy are categorized by EPA as "special wastes" and are
radioanalytic .data on these loads from FBP that you could share with us, we would be extremely grateful.
Thanks,
Curt

Prohibitions -- Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id=8502

2
GP270
offense.
radi~activity r~c~sor soils'.or ~ac~grou~~ radiation, but instead ~Jl~r$~1a
or
~~l~~~~~T~~{j~~~~~f~Ws:i@~4tioi9gi~ai1y.e~halic~d by.co!l~rQY1alft~.px~f~I[~~.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
ail: curt.pendergrass@ky.gov
y your fees on line at https://prd.chfs.ky.gov/rad epay/
~

Brine
attatchment

3
GP271

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.

4
GP272
, k forward to hearing from you!
George
(jeorge P. PartridiJe Jr.., Pli'D, P.'E., Q.'EP

200 Fair' Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
I,


Office: {304)356-4303
Fax: (304) 558-0524
GP273

To: Frame, Jason R
Hello Mr. Frame,
. -----~IENORM Services of Liberty, KY (http://advtenorm.com/ ). _We _will_foJ~yv-~jl~_i!h_the__<:~rnPan~presiden~~C()ry_____ ~-- ~~-- _
and Environment Cabinet Division of Waste Management since they regulate landfills here in KV.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of unwanted
sources http://www.crcpd.org/StateServices/SCATR.aspx
..
~

Mr. Pendergrass,

Office: {304)356-4303
Fax: (304) 558-0524
GP274

To: Frame, Jason R
Hello Mr. Frame,

disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously
.ludes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
is required.
..A
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
I.
plying to this message and delete this e-mail immediately. Nothing in this
munication, either written or implied, constitutes or should be construed as a
g y binding agreement between the parties with respect to the subject matter
herein.
7
GP275

Dr. Pendergrass,
~~-------- ------- US1ng tnese rvices-pr"Oviae-d-by-Adv-an-ce-d-TE'NORM-s-e"rvicestL~L.t---- -----~-~-------"-'-- - ---~https://a pp.sos.ky .gov/ftshow /( S(30yqolkfdaebcz4h poreem p4 ))/defa ult.aspx? path=ftsea rch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP276
&,.
Subject:
Attachments:

Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH); Partridge,
George (EEC)
FW: TENORM in KY
KRS%20211.859%20Central%20Midwest%20Interstate%20Low-Level%20Radioactive%
20Waste%20Compact.pdf
Hello gentlemen,
Looks like I had a telephone conversation with Mr. Cory Hawkins, Managing Member of Advanced TENORM Services LLC
way back in April of last year. See e-mail below. I did in fact share the KY regulatory statutes regarding the Central
Midwest Interstate Low-Level Waste Compact with Cory and let him know that the definition of NORM in the CMC
would encompass TENO RM produced as a result of oil and gas exploration and production. Looking back on our
conversation, I wish I had also informed him in writing of the fact the compact forbid the disposal of out of compact
wastes here in KY and if such waste were disposed, penalties could be assessed. But as they say, ignorance of the law in
no excuse.

shall. be the exclusive regulatory responsibility of the states, except thatno person
211. 865, or fails to comply with any order of the cabinet issued pursuant to KRS
offense.

Mailstop HS1C~A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
502-564-1492
ail:
curt.pendergrass@ky.gov
1
GP277

'.~;;..,,.
.. ~
....~..
. tTC1 ~
. _JIJ...;:!I
P.AtllA1'M:>ltHEAt.'l'H
Sent: Wednesday, April 15, 2015 8:49 AM

To: 'Cory Hoskins'
Subject: TENORM in KY
It was a pleasure speaking with you this morning regarding the disposal of TENO RM contaminated wastes from the oil
and natural gas industries. Until you called, I was not even aware that your company, Advanced TE NORM Services, LLC
existed much less was headquartered in Ashland, KY. Looking at the KY Secretary of State's Office it appears you and
your significant other have started this company fairly recently, at least here in KY
(https://app.sos.ky.gov/corpscans/60/0904260-06-99999-20141208-AOG-6004652-PU.PDF ). I will most definitely add
you to my TENO RM contacts and if and when we and our colleagues in the Energy and Environment Cabinet Division of
Solid Wastes and Hazardous Waste ever get around to drafting some TE NORM regulations for our cabinets and are
reaching out to the public and stakeholders for comment, we will most definitely be contacting you. Attached is a copy
of the KY Regulatory Statute dealing with ttie Central Midwest Interstate Low-Level Radioactive Waste Compact signed
between KY and IL. See http://www.lrc.kv.gov/statutes/statute.aspx?id=8498 or the CMC website at
http://www.cmcompact.org/ for more information. Our KY Revised Statutes 211.862 Definitions for KRS 211.861 to
211.869. actually defines NORM as follows
(http://www.cmcompact.org/statutes/KRS%20211.862%20Definitions%20for%20KRS%20211.862%20to%20211.869.pdf
):
(8) "Naturally-occurring radioactive material" (NORM) means naturally occurring materials not regulated under
the Atomic Energy Act of 1954, as amended, whose radionuclide concentrations have been increased by or as a
result of human practices. Naturally occurring radioactive material does not include the natural radioactivity of
rocks or soils, or background radiation, but instead refers to materials whose radioactivity is technologically
enhanced by controllable practices (or by past human practices);
Obviously this definition would encompass TENORM produced as a result of oil and gas exploration and production.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Kr!J..tutir~
-."""'~....~!/.
P:Atr!Ji(TION ;.u~..'\iTH
GP278
Cc:
Subject:

Frame, Jason R
Thanks Jason. That is exactly what I was hoping to hear. A WV regulation referencing a drive through radiation portal
alarm of 2X background and 5 pCi/g Ra-226/228 above background, would be great if you can send me a link. Also,
actual radiochemical data on the loads in questions would be extremely helpful. Does WV actually make companies like
Fairmont Brine conduct radiological surveys and radiochemical analysis of oil and gas production fluids? I know that
Republic Services operates many landfills here in KY and it is a company policy that all Republic laridfills have drive
through radiation portal monitors. We get our share of alarms for medical wastes in sewage sludge, usually long-lived
isotopes such as 1-131 which has a 8 day half-life. We even had a Republic landfill outside Ashland KY get a medical
isotope alarm in a waste load from Huntington, WV not too long ago. That load was found to contain Tc-99m which
meant that with a 6 hour half-life, the wastes was pretty fresh.
Thanks again for all your assistance.
~ East Main Street
.ailstop HSlC-A
Frankfort, KY 40621 .
.
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
u.a'
.intiif/Jr~..~.
1;!;~--~!'
pJl,tf!ATlONAHE/4. TH



background analytical limits. I may alrec:idy have data for the loads. Will check.
~Aon R. Frame B.S. R. T. (R), Chief Radiological Health Program
9;;,~e ofEnvironmental Health Services/Radiation, Toxics and Indoor Air Division

1
GP279
Office: (304)356-4303
Fax: {304) 558-0524
Sent: Friday, February OS, 2016 10:05 AM

To: Frame, Jason R
Hello Jason,
them for actual data on these loads. as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I wo. uld
presume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID . .
number was the radioanalyticaf analysis of this wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on
&.
sludge . The West Virginia Department of Environmental Protectio

processed FBP's Notification of Regulated Waste Activity Form. A~
Also, I remember seeing something in the lay press about WV issuing new regulations regarding TENORM. However, I
(http:(/apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping that you can share copy or a
link to the actual WV regulation which references this TENO RM limit for disposal in WV. I believe OH chose to use this 5
GP280
background. This does not apply to consumer or retail products which are discussed in
Subdivision 16.12.c. and Subsection 16.13. Usingpuryoseful dilution to render TENORM
waste exem t shall not be allowed without prior agency approval.
I ..
Just to let you know, while KY lacks specific regs addressing TENORM, our Central Midwest Interstate Low-Level Waste
'
Thanks,
Curt

KRS
211 ..862(8)
(3) Naturally-occurring radioactive material (NORM) as defined i.n
shall be.t~e e,xdu~iveregulato~y~esp~~si~iltty o.fthe st~tes, ~,x.~epi.~t}i~f'.~crp~f~().11
1
~~~~,~~~rw11~~-~~\~i~d~~~t41~~lW~~w~1~~~t~k;
irtB:~.imtiofis '.br4aiS:tiO$'a1art:'iITCbnsl.st~nt. with p olices .offhe commlssion'.
~- _- ~-:-~~:: ---~<-.:.-,;;..:,""'~r,.~: -,.J:,,.;..:..""'~~",s..c- __""-' 1:::'.2,-,,~~,;" _,;;-~--~'"?:~- -.~ _.;_,,. ,.::;_,,;;,;_,_-_,,_~-; .. "'-~.J..,,,,;,
..
-__ -.,_
j;-
..-_ ;,::.-.
" -.: .. .~
_\, ,____ ":o..-~
~, -., . ~-; -->.. /- , , --- '-. : ~ .. s--~~-,L""
.-J

offense.
practices. Naturally occurring radioactive material does not includet~e.nat~ral
radi?acti~ity ,of ~~cks. o~ ~oils, or background radiation, but inste.ad f~I~t0~~
~~~~~~~~k~~~~~~~~i~~1%:~s:.t~~~h~1~gic~nyel1!ianset1 ])y~ontr9lit~t~"Pr:~~!a~~

East Main Street

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
3
GP281
Fax:502-564-1492
'~

The form or appearance of the waste when it was shipped (before solidification}. What does it look like?
Brine
attatchment

Office: {304)356~4303
Fax: (304) 558-0524

4
GP282
To: Frame, Jason R

~ject: RE: TNORM disposal in KY
~on;
TENORM disposal.

confirmed the understanding we have ofthe situation before we move forward with site visits.
f!/Ao our Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
George
(1eor9e P. Partridge Jr., Pfi'D, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

5
GP283


---- _...OJfice:..(304.)35.6.::4303__ -~ -- ------ -- ---- -- -------- -- .. - - - -- . ----
-------.- - --- ----- -- -- ------
Fax: (304) 558-0524


To: Frame, Jason R
Hello Mr. Frame,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
6
GP284
'

ose of unwanted sources http://www.crcpd.org/StateServices/SCATR.aspx
,~,

Mr. Pendergrass,
I apologize for digging up this old email, but I don't believe I received any further response. I beiieve a company

Office: (304)356-4303
__..: (304) 558-0524

r . a i l : Jason.R.Frame@WV.gov

To: Frame, Jason R
tl!...o Mr. Frame,

7
GP285
'
is required.
Regards,
_____Sup_eot1sol'",_RadioactL~eJ11aterials_Section~C-~ _________ _
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
'


Dr. Pendergrass,
999 ). From Mr. Frames understanding, Advanced TE NORM Services L.L.C. (located in West Liberty, KY) will be solidifying
Frankfort, KY 40601
Ph: 502-564-3700 x4179
8
GP286
Cell: 502 330-7662

FAX: 502-564-1492
ICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
ain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
..
GP287
To:
Cc:
Subject:

The key to that rule is that it only applies to drill cuttings. What we are talking about from Fairmont Brine is not drill
cuttings. There are no disposal criteria for other materials.

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Republic Services operates many landfills here in KY and it is a company policy that all Republic landfills have drive
meant that with a 6 hour half-life, the wastes was pretty fresh .
nks again for all your assistance.

1
GP288

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
_____p~Y-Y-OUdees_onJinaatbttps_:ipn:Lchfs.k.gmdracLgp_ay:L~---~-
------~---
______ ________ ___ _____ _______,_._________ --~-----~
Be notified of proposed regulation changes https://secure.kentuckv.gov/Regwatch/

VnnfU
- '~,
l~~--A> -J:",Ati);.WJON ~All~AL't}l


Office: (304)356-4303
Fax: (304) 558-0524
..

To: Frame, Jason R
Hello Jason,
GP289
. e m for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I would
~esume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
sludge . The WestVirginia Department of Environmental Protectio

background. I am assuming FBP analyzed the loads in question and determined .they exceeded this WV limit. Also, I am
I
Compact of which KY is a member along with IL, specifically prohiqits the disposal ofout-of~compact wastes here in KY.
Thanks,
Curt

Prohibitions .. Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id=8502
(3) Naturally-occurring radioactive material (NORM) as defi~ed in lqlS 211.;~~~(8)

shall be the ex:dusive regulatory responsibility of the. states, ~l~tpf,t~~l~Q~"'~6p'
~~1i~~-1~~:~~~:.~~i~~;~~#j~f~i~i%g~~~~i~t~~~l~~r~~~~tl~ .
3
GP290
211.869 Penalties. http://www.Irc.ky .gov/statutes/statute.aspx?id=8505

--- ---~----uffenKe-:----------_----~~~-~--~-~-~-~~---~-------------------~------------~---~--~-----~~~---- -
'

http://www.lrc.ky .gov/statutes/statute.aspx?id=8501
practices. Naturally occurring radioactive material does not includet?e.~atural
radioactivity of rocks or soils,or background radiation, but instead l"~f~fs~i()'
[gf~~~ftl~l~~rr~it~~11ir~fqg1~~Jty~eAi1~I1c:~cf~y!6ff~t:r~1r~~wpf~ctfd,~~-
~~~~i~:~~f

Supervisor, Radioactive Materials Sec_tion
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700
ext. 4183
,r
Fax: 502-564-1491
l(.elftu - --f<AD;'~1i.Alm


Name of company in Fairmont along with County that_ contracted with Advanced TENO RM Services. Fairmont
Brine
4
GP291
attatchment
~ason
R. Frame B.S. R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
II
'-------------~----------

--
To: Frame, Jason R
I,

Jason;
TENORM disposal.
I

Any knowledge where it was sent for solidification in Ashland, KY (?) prior to being sent to the landfill .
GP292

-0~-looJdorw_acd_to_be_aringJrnmy_ouL_ -~-
George
(jeorge P. Partridfie Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
I

Office: (304)356-4303
Fax: (304) 558-0524
GP293

To: Frame, Jason R
Hello Mr. Frame,
oskins, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
nd Environment Cabinet Division of Waste Management since they regulate landfills here in KY.
'
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
om: Frame, Jason R [mailto:Jason.R.Frame@wv.gov]

: Pendergrass, Curt (CHFS DPH)
7
GP294
Mr. Pendergrass,

---C--h--a-rles-ton1Wes-t-Virgi nia-25301- - - ---- -- --- Office: (304)356-4303
Fax: (304) 558-0524
I

To: Frame, Jason R
Hello Mr. Frame,

generated in the oil and gas industry from hydraulic fracturing, we do have statutes on the books establishing the Central.
is required.
Regards,
Mailstop HSlC-A
GP295
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
~ax: 502-564-1492
. h i s e-mail and any files are protected by the Electronic Communications Privacy
herein.

Dr. Pendergrass,
tt s: a .sos.k . ov ftshow S 30 olkfdaebcz4h oreem 4 default.as x? ath=ftsearch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP296

.ailstop HS1C-A
-~ankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Pay your fees on line at https://prd.chfs.ky.gC>v/rad epay/
Dispose of unwanted sources http://www.crcpd:org/StateServices/SCATR.aspx
Nz!J!J~
r{AtiJATIO~lAH~.t.TH

that we developed with WVDEP which set ~ate alarms of 2x background and then 5 pCi/g radium 226/228 above local
background analytical limits. I may already have data for the loads\ Will check.
ason R. Frame B.S. R. T. (R), Chief Radiological Health Program

ffice of Environmental Health Services/Radiation, Toxics and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524
Sent: Friday, February OS, 2016 lO:OS AM

To: Frame, Jason R
~: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)
rbject: RE: TNORM disposal in KY

Hello Jason,
3
GP297
them for actual data on these loads as fo the activity concentration of Ra-226 + Ra-228 plus daughter products? I would
sludge.. The West Virginia Department of Environmental Protectio

--~---fnvironrnentat Protection :Agency (OS-E'PA11ltenfificat1on Numoer~-~
I
exempt from federal hazardous waste regulations urider Subtitle C of the Resource Conservation and Recovery Act
Thanks,
Curt


..
shall be the exclusive regulator responsibility of the states,
::;~~,~;~{~:;;":Y:&~~~-
-:~~:(~~.::r~;r
-::.~;J";~::"::';:r_,~~-
-"
GP298
'

offense.
http://www.Irc.ky.gov/statutes/statute.aspx?id=8501
radionuclide coi;icentrations have been increased by or as a result of human
r~dio~ctivityof.rocks;?r. ~oils., or b.ac~~round. ra4iation, but in.steadf~f~~~'.;t<)
~~i~~~~~C~~i~~f~~~~~l~~!{fosn~~{c)gi,gally~rih.l~~ecl l1ycqi11i2lli~ff;.p!:~,~i!~i~~
5 Ea.st Main Street

ailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
,~:,

".
Brine
5
GP299
attatchment

Office: (304}356A303
~---
..
~(~e4+.-s-ss-es~4

To: Frame, Jason R
Jason;
TENORM disposal.

The form or appearance of the waste when it was shipped (before solidification}. What does it look like?
Name of company in Fairmont along with County that contracted with Advanced TENORM Services .
Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent to the landfill .
GP300
~lso our Assista nee Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
George
<jeorge P. Partrit:fge Jr., Pfi'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651



Office of Environmental He.alth Services/Radiation, Toxics and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524
GP301

To: Frame, Jason R
Hello Mr. Frame,
'

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
~~

8
GP302
Mr. Pendergrass,
~pologize for digging up this old email, but I don't believe I received any further response. I believe a company
9'5P.erating as "Advanced TENORM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524


To: Frame, Jason R

Hello Mr. Frame,
regulatory purview. Ohio and Pennsylvannia both have regulations addressing the disposaJ of NORM/TENORM
is required.
Regards,
~rt Pendergrass,
Ph.D.
pervisor, Radioactive Materials Section
adiation Health Branch
Mailstop HSlC-A
9
GP303
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
'
-Pl'"Obibited.-Jf_you~bave-rec:eived-tbis-e.,,mail~in error-rplease-notif)cthe-sender-- by replying to this message and delete this e-mail immediately. Nothing in this
herein.

Dr. Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
review, use, disclosure, distribution or copying of th.is communication is strictly prohibited. If you have received this communication in error, ple<1se contact the
10
GP304
._rom:
Sent:
To:
Subject:
Attachments:
Maze, Rodney (EEC)

Fwd: Green Valley
Green Valley Landfill sign in sheet 02-04-15.pdf; ATTOOOOl.htm; Green Valley
Landfill(2015 Tenorm Waste Documentation).pdf; ATT00002.htm; Green Valley
Landfill(2016 Tenorm Waste Documentation).pdf; ATT00003.htm
Attached is the Tenorm waste documentation from Green Valley Landfill we obtained yesterday during the site visit
Rodney Maze
Begin forwarded message:
From: "Butcher, Deborah (EEC)" <Deborah.Butcher@ky.gov>

To: "Maze, Rodney (EEC)" <Rodney.Maze@ky.gov>
Subject: Green Valley
'
Deborah Butcher Witt

Administrative Specialist Ill
Department For Environmental Protection
Morehead Regional Office
Divs ion of Waste Management
525 Hecks Plaza Drive
Morehead, KY 403 51
606-783-8655
GP305
To:
Cc:
Subject:
Attachments:

FairmontBrineRadchem.pdf
These results were provided to me by Waste Management while they were involved with the project. The said this was a
combined average of the loads, but I did not specify the sampling methods so can't speak too that.

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
, e a n t that with a 6 hour half-life, the wastes was pretty fresh.
GP306

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
-~~- __W.ebsite:.bttpj_f___www~chfs_ky_gov/_dpb/radioactiv.e_btm ___ _
Nztf/JJ .~
f"..-'\r!lATlOl ~ &.H~'J.. TH


'

Office of Environmental Health Services/Radiation, Toxic'5 and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524
From: Pendergrass, Curt (CHFSDPH) [mailto:Curt.Pendergrass@ky.gov]
To: Frame, Jason R

2
GP307
Hello Jason,
rem
i a v e huge favor to ask of you. Is there any way that you can contact Fairmont Brine Processing in Fairmont WV and ask
for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I would

processed FBP's Notification of Regulated Waste Activity Form" A~
Environmental Protection Agency {US EPA) Identification Number
more of a proposed rule and not an ac;tual regulation
'
Just to let you know, while KY lacks specific regs addressing TENO RM, our Central Midwest Interstate Low-Level Waste
Thanks,
Curt

(3) Naturally-,occurring radioactive material (NORM) as defi11e~ in ~~211.~62~8)

shall be.the .excl.usive regulatory responsibility ()f the states, ~~9.epttb~~i\t>.'.iJ~~1If
~!l~li:tfiJ.i?'Q~~ii~!R~~lWk~~"9~Q:i~~;f\4.1~i9tfye:m~!~rigI {NQ~),tf.C>rriqt{f,~)d~tti~
3
GP308
r~gioif9t,c{fspQs~ i? ~~~t~~*f; or dispose:qf~'s~'ghjmported Ilraterial in Kent~Q!iy;

ff tJ:i~ lpl.p()rt'~r~gisp(jsj'.;~fl::t1Jcoiisistent.withpollces of the commission;.
'

''-~(-$+00;000}:-Eaeh-daroHhe-vfolatiem-or-noncomphance-shaH-constitute-a-separate--------~--~----- -~----~~--
offense.
practices. Naturally occurring radioactive material does not include t~e natural
radiation, but
instead r@.f~t~1d
radioactivity of rocks or soils, or background
s:
.:--.---",,'< '' materials':whose;taaibactivit~ \is'.feelinmt'.'l-1can enhanced 'b. ~corttro11able' ractrees
C~f~h~'It~~I'.~~tit~j5~ti~'.~)l
g~ j~"'-~"'''' .Y,... ~,.. , , ,,P ... .<. .. ,
f:?{';'>----~:Z~fi:':-:--;;-7.'=~:c--:'_-,::- ,.'"";.,o;>:,~
<_:-_,: _:- .;..c- f:-7c--;>".' ;~:",:;;_"f}::,:;7,--=;;sHc;:;;;,,.,,,,_~/!>: C'.?::C .-,,,,~;:_:;,- ''~-""7!'"':';.-
,........
>''"- ,,-:\-r;J" "(~< 9":, ,.,_, :--,",_
;~
J:>'..,;~~77'!,_,:'J-,,"fi!,,:(
;;:. ",? ,. -
, ,-, -- .-..- .T~ :,
---?~,--;

275 East Mai.n Street
Mailstop HSlC-A
Frankfort, KY40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
E-mail: cur:t.pendergrass@ky.gov
Website: http:/fwww.chfs.ky.gov/dph/radioactive.htm
"""

Oates and time period the shipments were sent. Shipments occurred during August 2015 .
4
GP309
,.
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Jason;
TENORM disposal.

5
GP310
'

George
(jeorge P. PartrUfae Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
'

To: Partridge, Ge1Jrge (EEC)
Jason R. Frame B.S. R. T. {R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
GP311

To: Frame, Jason R

Hello Mr. Frame,
oskins, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
nd Environment Cabinet Division of Waste Management since they regulate landfills here in KV.
'
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
E-mail: curt.pendergrass@ky.gbv
Website: http:ljwww.chfs.ky.gov/dph/radioadive.htm
~,
ent: Tuesday, January 19, 2016 12:51 PM

o: Pendergrass, Curt (CHFS DPH)
7
GP312
Mr. Pendergrass,
I apologize for digging up this old email, but !don't believe I received any further response. I believe a company
'

--------------------~----GhaFlesten,-WestNir.ginia-2-391-~-- --~---
Office: (304)356-4303
Fax: (304) 558-0524
----------------
~~~-
I

To: Frame, Jason R
Hello Mr. Frame,
is required.
Regards,
Mailstop HS1C-A
I
8
GP313
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
~ax: 502-564-1492
l'this e-mail and any files are protected by the Electronic Communications Privacy
herein.

Dr. Pendergrass,
tt s: a .sos.k . ov ftshow S 30 olkfdaebcz4h oreem 4 default.as x? ath=ftsearch&id=0904260&ct=06&cs=99
the "tacking" sludge in Ashland, KY and then sending itto a Class D landfill in Irvine, KY. Mr. Fame's question was in
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is a.ddressed and may
GP314

Frame, Jason R
To:
Cc:
Subject:
Thanks Jason. Do you know why WV chose to exempt "wastes generated during the completion process or derived from
the hydraulic fracturing process, including but not limited to, flowback solids and liquids, brine, tank bottoms, pit
cleanout material and sludges, filters and filter media, pipe scale, used track sand and proppants, etc."? Was that due to
industry push back? I believe OH also issued a broad exemption in its TENO RM regulations as well but those applied
strictly to oil and gas production operations in OH and not those from out-of-state.
https://www.odh.ohio.gov/~/media/ODH/ASSETS/Files/rules/final/3701 1/37011-43/37011-43-07.pdf I doubt WV
would allow a company from KY to bring these same wastes produced in KY into your state for disposal.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
. x : 502-564-1492
9_-mail: curt.pendergrass@ky.gov
Dispose of un~anted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
UnnfU
~ti..

http://apps.sos.wv.gov/adlaw/csr/ruleview.aspx?document=9530
5.6.a.1. "Drill Cuttings and Associated Drilling Wastes" means the broken bits of solid material and drilling mud removed
from a borehole drilled by rotary, percussion, or auger methods, but does not include wastes generated during the
completion process or derived from the hydraulic fracturing process, including but not limited to, flowback solids and
liquids, brine, tank bottoms, pit cleanout material and sludges, filters and filter media, pipe scale, used frack sand and
proppants, etc.
6.d. Radiation Monitoring
GP315
5.6.d.1. All Solid Waste Facilities that accept drill cuttings and associated drilling waste for disposal must
install fixed radiation detection equipment at the entrance to the facility. All drill cuttings and associated drilling wastes
generated in the exploration, production and development of oil and natural gas and associated activities must b e .
evaluated by this equipment. The facility must also have a portable radiation monitor capable of determining dose rate'
and the presence of contamination on a vehicle. The facility shall provide staff with documented training in the
operation of all onsite radiation monitors.
5.6.d.2. The fixed detector must be capable of measuring exposure rates from ten microroentgens per hour
{10 R/hr) to greater than fifty mi Iii roentgens per hour (>50 mR/hr.). The instrument must be maintained and calibrated
_____ .according tomanufactur.ecspecifications. _____, __ _ __ ___
______ __ ___ .. ------~-"-- .. _____ _
5.6.d.2. The detector elements must be configured to be as close as practical to the waste load and in an
appropriate geometry to monitor the waste.
5.6.d.3. The facility shall set the detector to sound an alarm if the reading on the detector exceeds
lOR/hr. above local background.
5.6.d.4. If a load of drilling cuttings or associated drilling waste is confirmed to be less than ten
microroentgens per hour (10 R/hr.) above local background level, the waste may be disposed of in the facility. If the
load of waste is confirmed to be equal to or greater than 10 R/hr. above local background level, the combined
concentration of Radium 226 and Radium 228 must be determined. The combined concentration must be analyzed by a
State approved method. If the combined concentration in the waste is less than five picocuries per gram (5pCi/gr.)
above local background level, the waste may be disposed in the facility. If the values are greater than 5pCi/gr. above
local background level, the load must be rejected.
5.6.d.S. For each radiation alarm generated the facility shall provide an incident report to both the West
Virginia Department of Environmental Protection (DEP) and West Virginia Department of Health and Human Resources
(DHHR) Radiological Health Program using Form lW Solid Waste Radioactivity Reporting Form within 24 hours of the
initial alarm. Form lW can be obtained by contacting the DHHR Radiological Health Program.
5.6.d.6. Solid Waste facilities accepting drill cuttings and associated wastes must submit and obtain
approval from both the DEP and the DHHR Radiological Health Program of a Radiation Monitoring Plan that outlines the
facility's procedures for managing the waste.
5.6.e. A commercial solid waste facility located in a county that is, in whole or in part, within a karst region as
determined by the West Virginia Geologic and Economic Survey, may not accept drill cuttings and drilling waste
generated from horizontal well sites.

Office: {304)356-4303
Fax: (304) 558-0524
GP316

To: Frame, Jason R
Republic Services operates many landfills here in KY and it is a company policy that all Republic la.ndfills have drive
otope alarm in a waste load from Huntington, WV not too long ago. That load was found to contain Tc-99m which
eant that with a 6 hour half-life, the wastes was pretty fresh.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Una.tu.. ~~
IW.~-

nt: Friday, February OS, 2016 10: 18 AM

3
GP317

Office: (304)356-4303
.ax:-(304.)S58=D52~L .... ~~-----

To: Frame, Jason R
Hello Jason,

Environmental Protection .Agency (US EPA) Identification Number

4
GP318
Thanks,'
Curt


shall be the exclusive reglllatory responsibilityof the states, eff~t~t~~ti~9Ji~t~~
''''"''"' l:~~~~ITT~,~~?tl~~i~~~l~tv~~
1
~~~,~~1,.,,J1J:'.H;~:.,z'h~~~;"t~':i~~"'"''".. '"'n'""-'''~iY~i~teQtwJth:P9li~.~~1gf th~.co{Ilmi~~.~iQ~.

offense.
practices. Naturally occurring radioactive material does not include the .natural
radioactivity ofrocks or. soils, or bac~wol1nd radiation, but instea,d t~f~~~~i~...........
mf!~~ll~f~~="''
<~~~,:~~,.~;~:'~3~)i;i~1miilQgfo.~iy.~Qh~~c~{hy;cgnttgiJ~g:J~.~f~~tf~~::
5
GP319

Supervisor, Radioactive Materipls Section
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
---- ___::.rnail=-curt.p_e ndexgr...ass_@kJw~-----~~


Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
GP320

To: Frame, Jason R
Jason;
TENORM disposal.
# , o u could provide additional information related to our conversation about the shipments by Advanced TENORM

The form or appearance of the waste when it was shipped (before solidification). What does 'it look like?
Name of company in Fairmont along with County that contracted with Advanced TENORM Services .
- k forward to hearing from you!
George
7
GP321
(jeorge P. Partrilfge Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Jason R. Frame
B~S.
R. T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
Email: Jason.R;Frame@WV.gov
'

To: Frame, Jason R

Hello Mr. Frame,
8
GP322
,.askins, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
.11Prd Environment Cabinet Division of Waste Management since they regulate landfills here in KY.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky .gov Id ph/ radioactive. htm
..
"
~
...~.. , f.f>.;:,
'.
~,..,,
rtA!ttA'ffQ.N.A.iiatuJtH
~m: Frame, Jason R [mailto:Jason.R.Frame@wv.gov]

Cc: Webb, April (EEC); George.Patridge@ky.gov;
Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
GP323

To: Frame, Jason R
Hello Mr. Frame,

is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
10
GP324
&.

: jason.r.frame@wv.gov
Dr. Pendergrass,
https:f/app.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
502 330-7662
-=~X: 502-564-1492
_a11:
11
GP325
To:
Cc:
Subject:
Attachments:

Friday, February 05, 2016 12:06 PM
Frame, Jason R
Thanks Jason. Unfortunately, the analysis of the FBP wastes by Pace Analytical appears to be devoid of radioisotopic
analysis, or even total radium. Looks like we may be digging up dirt here in KY.

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
.
_Anotified of p.roposed regulation changes https://secure.kentucky.gov/Regwatch/
.spose of u~wanted sources http:Uwww.crcpd.org/StateServices/SCATR.aspx
Kf!x .


Office: {304)356-4303
Fax: {304) 558-0524
..
1
GP326

To: Frame, Jason R

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Kc!JJU~
Sent: Friday, February 05, 2016 10: 18 AM


2
GP327
'
,kground analytical limits. I may already have data for the loads. Will check.
Office of Environmental. Health Services/Radiation, Toxics and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524
m: Pende. rgrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]

t: Friday, February 05, 2016 10:05 AM
Frame, Jason R
Hello Jason,

processed FBP's Notification of Regulated Waste Activity Form, A!
ming this limit is based on protecting public and health and safety of the citizens of WV but what I saw seemed to be
e of a proposed rule and not an actual regulation
p://apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping that you can share copy or a
3
GP328
Just to let you know, while KY lacks specific regs addressing TENORM, our Central Midwest Interstate Low~Level Waste
and production of crude oil, natural gas, and geothermal energy are categorized by EPA as 11 special wastes 11 and are
Thanks,
Curt

'
211.869 Penalties. http://www.Irc.ky.gov/statutes/statute.aspx?id=8505
(1) Any person who fails to comply with any provision.of KRS 211.859 or 211.863, or
offense.
(8) Naturally-occurring radioactive material" (NORM) means naturally occurring
radioactivit of rocks or soils, or back~!ound radiation, but inste~d.f~~i-~&
11
;!f}~~~~~f~~ify~JRg!~Mi-J~till~W~~l'.l~J?Y:92Jt~~~1l~~!~.~i~~~t9~s
4
GP329

~~tucky Radiation Health Branch

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
--

Brine
attatchment
Jason R. Frame S.S. R. T. (R), Chief Radiological Health Program

Office: (304)356~4303
Fax: (304) 558-0524
..
5
GP330

To: Frame, Jason R
Jason;
TENORM disposal.
Number and type of trucks/ volume, etc. ofthe wastes .

Name of company in Fairmont along with County that contracted with Advanced TE NORM Services .
George
6
GP331
'
<;jeorge P. PartridiJe Jr., Pfi'D, P:E., QXP

~~ Fair Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
....._9


Capitol Street, Room 313
1111!!'3rleston, West Virginia 25301
.,_,ffice: (304)356-4303
Fax: (304) 558-0524
JIJ..O

To: Frame, Jason R
...._9 McKinley, Matthew W (CHS-PH); Brock, Stephanie C (CHS-PH)
pt>ject: RE: TNORM disposal in KY

Hello Mr. Frame,
GP332
L.
...

Supervisor, R~di?active Materials Section
~~--~Kentucky~Rad1at~Gn~l-lealt/-t-lil!'"anch-----
------ ~- -- --~---- - -- --- 275 East Main Street

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
--~~~--~----------------------------------~
'~

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
GP333
'

To: Frame, Jason R
.Cc: Webb, April (EEC); George.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Hello Mr. Frame,
west Interstate Low Level Radioactive Waste Compact of which KY is a member with IL. The compact strictly forbids
udes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
This e-mail and any files are prot~cted by the Electronic Communications Privacy
plying to this message and delete this e-mail immediately. Nothing in this
munication, either written or implied, constitutes or should be construed as a
g y binding agreement between the parties with respect to the subject matter
herein.
.!
GP334
..

Cc: jason. r.frame@wv.gov
Dr. Pendergrass,
I was contacted this morning by Mr. Jason R. Frame; a member ofthe West Virginia radiation program. He was
- ------using tfie ser\tices prov1ffecfEJYAcfvancea-TENURM-servrtescccr----- ----~---------https://app.sos.ky.gov/ftshow/(S(30ygolkfdaebcz4hporeemp4ll/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
'
contain confidential information exempt from disclosure un_der applicable law. If the reader of this message is not the intended re9ipient; you are notified that any
review, use, disclosure, distribution or copying of th.is communication is strictly prohibited. If you have received this communication in error, please contact the
10
GP335

m:
Sent:
To:
Cc:
Subject:

??? page 24

Office: (304)356-4303
Fax: (304) 558-0524
Sent: Friday, February OS, 2016 12:06 PM

To: Frame, Jason R

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
502-564-1492
-mail: curt.pendergrass@ky.gov
1
GP336

Dispose of un~anted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx

______ ---- - --------- --- ----
-su6]ea:t{E:lr\JD~r\fa-1sposai---inl<Y
--~------- -'-~

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
alarm of 2X background arid 5 pCi/g Ra-226/228 above background, would be great if you can send me a link. Also,
2
GP337

~ East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
I((z:{f!JJ
r~;~t11trr1tir~
~,

'__ilckground analytical limits. I may already have data for the loads. Will check.
4';ason R. Frame B.S. R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524

~t: Friday, February 05, 2016 10:05 AM
~ Frame, Jason R
3
GP338
Hello Jason,
I have huge favor to ask of you. Is there any way that you can contact Fairmont Brine Processing in Fairmont WV and as~
them for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I would - presume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
number was the radioanalytical analysis ofthis wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on

----processeaFBP-,s~NotincatTon ofRegulated Waste Activity Form .. A! ___ _
Environmental Protection Agency {US EPA) Identification Number
'
Just to let you know, while KY lacks specific regs addressing TE NORM, our Central Midwest Interstate low-level Waste
radioanalytie data on these loads from FBP that you could share with us, we would be extremely grateful.
Thanks,
Curt


~lial!.~_etli~ ~~cl~si veregulatorr,;es~onsi?.~l.ity. of.the states,. ~~~~-;::;~~9:1R~t{~~
shf!lfamn~~~n~ill~11;;9~~fii1ng !:~ii!~~9u:imat~l'1<.i1:cNQ~)~tr', ......!Ji1~~!1lff

4
GP339
..

offense.
practices. Naturally occurring radioactive material does not include ~he ~at,ural
radioa~tivityo.f rocks orsoils, or.?ac~groun~ radiation, but instead r~f~fs'io'
~~~~~~~~~J~~~~g~~1~1fi.t~9@9i()gic(lll)r;ynh~!fce~.by. c.oritr(M~~1~jJf~fJ!M~~

ervisor, Radioactive Materials Section
ntucky Radiation Health Branch
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~

5
GP340
Brine
attatchment

-Gtlarlesten,Wes+ViFginia-i-53EJ1~- -~ - ~---~ --- -- Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.

Dates and time period the shipments were sent
.6
GP341
rrifirmed the understanding we have of the situation before we move forward with site visits.
George
(jeorge P. PartrUfoe Jr., Pfi1J, P.'E., fl'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


350 Capitol Street, Room 313Charleston, West Virginia 25301
Office: (304)356-4303
Fax: (304) 558-0524
GP342
To: Frame, Jason R

Hello Mr. Frame,

Hoskins; and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Pay your fees on line. at https://prd'.chfs.ky.gov/rad epay/
Be notified of proposed regulation changes https:Usecure.kentucky.gov/Regwatch/.
Dispose of unwanted. sources http://www.crcpd.org/StateServices/SCATR.aspx
,,,~".

8
GP343
'
Mr. Pendergrass,
ologize for digging up this old email, but I don't believe I received any further response. I believe a company
rating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,

is required.
Regards,
~ Pendergrass, Ph.D .
Mailstop HS1C-A
GP344
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
~----- ____ probibitedLILyou_bay_e_receiy_ed_tbis~e~aiLin_e[[0[1_pJease_11otify-1be_se11deL_ -------------~-~~-~-.-----~-~-~~----- __
herein.

Dr. Pendergrass,
htt s: a .sos.k . ov ftshow S 30 olkfdaebcz4h oreem 4 default.as x? ath=ftsearch&id=0904260&ct=06&cs=9
275 East Main Street, HS1 CA
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you ate notified that any
review, use, disclosure, distribution or copying of this communication is strictly prohibited. ff you have rece(ved this communication in error, please contact the
10
GP345
efom:
Sent:
To:
Subject:

FW: TENORM Environmental Monitoring
fyi

To: Aldridge, Louanna (EEC)
Louanna,
Radium-226
Radium-228
Polonium-210
Lead-210
-forms from the decay of radium; preferentially follows other gases;' can end up in landfill gas, prefers ethane
-~~ propane. Will eventually end up being released through the landfill or gas system into the air,
,,,_9don
Groundwater: A landfill that has accepted TENORM should already have a functioning groundwater monitoring system
be an issue.
,ways.
If you have any other questions, please feel free to ask:
GP346
Regards,
Todd

Geologist
Solid Waste Branch
200 Fair Oaks Lane
-------~-Frankforti-~Y-40601~-~- -----502-564-6716 ext. 4653
'
GP347
Cc:
Subject:
Attachments:

Frame, Jason R
Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); McKinley, Matthew W
(CHS-PH); Anderson, Danny J (EEC); Loyselle, Maridely (EEC); Webb, April (EEC)
FairmontBrineRadchem.pdf; Fairmont Brine plan.pdf
Thanks Jason for pointing out my oversight on the attached radiochemical analysis of the sludge obtained from the oil
and gas production fluid processing tanks at Fairmont Brine Products (http://www.fairmontbrineprocessing.com/ ). And
thanks especially for the follow-up telephone call on what has transpired between your office and Fairmont Brine
Products over the years. I would say 1,453.5 200.78 pCi/g Ra-226 and 303.75 40.774 pCi/g Ra-228, not to mention
the elevated U-238 and Th-232 parents, is way over anyone's acceptable criteria for burying waste in anything but a
hazardous waste landfill specifically licensed for the disposal of radioactive material. Now that we know your office put a
halt to Fairmont Brine disposing of this material in WV and that the company then contacted Waste Management about
helping them to dispose of this material properly and that it was Waste Management who paid for the attached Pace
Analytical analysis and that it was Waste Management that told FBP that the material needed to be taken out west to a
licensed disposal facility and obtained cost estimates for that proper disposal, the fact that FBP then chose to accept a
much lower bid from Advanced TENO RM Services of West Liberty, KY (http:Uadvtenorm.com/) makes the company
culpable in my book. We will be meeting next week with our colleagues in the Division of Waste Management to decide
_ . w best to address this issue since the waste.sis now buried at several municipal solid waste landfills here in KY. Again,
. . . just can't thank you enough for all your assistance in this matter.
Have a great weekend.
Curt
"
1
GP348
ANALYTICAL RESULTS -RADIOCHEMISTRY

Project
Fairmont Brine - Sludge Pit Cl
P~ P:r'Qi<# ~o.:
aor~25~
sample: FairmQntBnne-Sludge Pit
Cl
~b ID: 30150255001
PW:s:
cone:cted: 08/08115 09:25
Reooli.te<f: OOJ.9911515:45
..
Mall
S;:irnpe Type:
Site.lD;
ft.suits' reporttJl:I on a #Ql}'<Welf]ht" basis
Param.etem
ljnllS.
AntimQny~t24
EPAOOt1
0.000.:f:0.674 (2.4>37)
C:NAT;NA
.
.
pevg
0&1$11!H6:51 1.
Cdbalt-6o
EPA1.1
pClfg
1511516:51 fl
lrid~.m.192
EPA001.1
.0.000 . 0.565 (1.683)

c:NA i:NA.
o.qoo :t 0.634 (U380)
pCi1"1
06/1511!? 16'.51 1
PdtaS(!;l.,im~o.
EPA001.1
pGifg
11i5tHH6:51_ 1;
Radium.,;225
EPASQ1.1
:21t63o19.~6 (17.1~
C~NA l:NA
1~.500.:t ~l)0.18(1 (4til30}
pcilg
00/1511516:51 1:
Raitium~
EPA001.1
303~1.SO.:t 40.774
~ifg
06/1511~16'.51
seaooium.46
EPA:901J
pCl/g
00/1511516:$1 1:
SilveM10M
EPA001.1
pCifg
00/1511516;51 1
Thort4.m~232
EPA001.1
162-:?00 J;392:170 (47lU)OO)
pClfg
ll6.!1511$1~:$1
Uranlurn-238
EPA~.1-1
94:336 1VI06 (17.780)

C~NA T:NA
pCifg
00l15/15.16::51
:c:NA.l:tllA
c:HA 11N~
c:HA T:NA
(7 .817)
1~:.tl.784 (1.174)
1.i
C:NAT:NA
~-3~1
t 1 ;67 (1.549)
C~NAT:fi,fA
c:tjA l';r.A .
.,.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
uen...m~~,
IV#i'tl!l<O

---
2
GP349

Ace of Environmental Health Services/Radiation, Toxics and Indoor Air Division
~Capitol Street, Room 313

Office: (304)356-4303
Fax: (304) 558-0524
m:
Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky~gov]
nt: Friday, February OS, 2016 10:36 AM

a;:_
~o: Frame, Jason R
alarm of 2X background and 5 pCi/g Ra-226/228 above background, would be great if you can send me .a link. Also,
Mailstop HS1C-A
Frankfort, KY 40621
502-564-3700 ext. 4183
502-564-1492
. lrx:
GP350
..

To:-Penoergrass, "Curt-(CRFSUPRr--O --- Cc: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Jason,
I have huge favor to ask of you. Is there any way that you can contact Fairmont Brine Processing in Fairmont WV and as&..
them for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I would,,,
GP351
num. ber was the radioanalytical analysis of this wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on
,
. '51udge. The West Virginia Department of Environme

processed FBP's Notification of Regulated Waste Acti
Environmental Protection Agency (US EPA) ldentiflca
Also, I remember seeing something in the lay press about WV issuing new regulations regarding TE NORM. However, I
,
Compact of which KY is a member along with IL, specifically prohibits the disposal of ouFof-compact wastes here in KY.
Thanks,
Curt

..
(3) Naturally-occurring radioactive material (NORM) as defi11edi~ ~S21!.8~~(8)

shall be the exclusiye regulatory resIJonsibility of the states, ~~~~p(~t~~fifq',J)~~~f>:~
='-'~" . .,.,,
i\ifi~\itl~~y\
r"~,.,,,. ~o:l~filk~1~tf

5
GP352
offense.
..
-------------littP://www.lrc.ky.wv/stalutes/statute.aspx?icl=8501-- -------~------- - -----
..
..
---

practices. Naturally occurring radioactive material does not include thep_atural
radio~cfrvity of.r~cks -~r soils_,_ or.background radiation,_but_i.nste~dJ_~f~s~t~
~~t~~~~~t~{::~~~i~~~~i~~~~1[~~Ftt&2J~g19~l~i~l1~~Iis~<l::~y~qJi~r9lX~~~~-I't~Mi~~s;

Kentucky _Radiation Health Branch
Mailstop HSlC~A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
'

Name of company in Fairmont along with County that contracted with Advanced TENORM Services. Fairmont . . . .
Brine
~
attatchment
6
GP353
...._9son R. Frame B.S. R.T. (R), Chief Radiological Health Program

p i c e of Environmental Health Services/Radiation, Toxics and Indoor Air Division
Office: {304)356-4303
Fax: (304) 558-0524
,

To: Frame, Jason R
Jason;
TENORM disposal.

Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent to the landfill .
7
GP354
'
George
(jeor9e P. PartridiJe Jr., PfiV, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
'


Office: (304)356-4303
Fax: (304) 558-0524
GP355

To: Frame, Jason R
l o Mr. Frame,
.hank you for the follow-up e-mail on the purported disposition of WV TENORM wastes here in KY by Advanced
and Environment Cabinet Division of Waste Management since they regulate landfills .here in KV.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
GP356

Cc: Webb, April (EEC); George.Patridqe@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)

Mr. Pendergrass,
~---Operating_as_"Adv_ancedIEl'JQRMSenLtcesl1Js_mntinuingto-1acUitatethe disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524
From: Pendergrass, Curt
DPH) [mailto:Curt.Pendergrass@ky.gov]

To: Frame, Jason R

Hello Mr. Frame,
;,,,>'
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this e- , . .
A..
10
GP357
is required.
~ards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein .

91 o: Pendergrass, Curt (CHFS DPH)
Dr. Pendergrass,
inquiring about a West Virginia company's intent to dispose of TN ORM from a "tracking" operation here in Kentucky by
Frankfort, KY 40601
Ph: 502-564-3700 x4179
...-~I_: 502 330-7662
~: 502-564-1492
11
GP358
elm:
Sent:
To:
Subject:

'bmcintyre@republicsevices.com'; 'twilfong@repblicservices.co'
RE: Regulation of TENO RM in Kentucky
Hello Bill and Tim;

It was a pleasure meet you both yesterday at Green Valley and discuss the shipments ofTENORM that has been brought
to the attention of the Division of Waste Management that are being received from out of state.
As Rodney Maze and I shared with you, TENORM is regulated by the DPH and the individual that stays in contact with
our Division regarding radioactive materials/waste is Curt Pendergrass. I have his contact information below. He is their
expert on TENORM. Curt and I have been corresponding the past several years and been concerned that eventually
TENORM wastes would be shipped in violation of KRS 211.863. The regulations that have been emphasized related to
TENO RM by the DPH have been inserted below along with Curt's contact information.
It is a pleasure to visit Republic Facilities and how conscientious your company is in seeing that everything is managed
well as illustrated by your facilities have calibrated detectors and all you do to manage the waste streams you receive.
Fortunately, we hope that any waste you have received is the low level TENORM and the TENORM waste that is at much
lher levels i~ being disposed further in the state at facilities that do not have detectors to screen incoming waste .
s we learn more how the shipments are being managed and disguised so the receiving facility will not recognize the
nature of the waste we will pass that information on to you as we continue to investigate this situation. We have
already identified individuals/companies involved in these illegal shipments and they are being investigated.
In closing, I want express our appreciation again to you both, that Rodney, Karen, and I could visit you and bring this
matter of concern to your attention. We appreciate all you are doing to support our efforts of curtailing receipt of this
TENORM waste.
As industry brings this to the attention of upper management in state government, that will encourage the development
of a regulatory and enforcement framework that will assure the safe management and disposal of TE NORM.
Please do not hesitate to contact me if I can be of further assistance or help with questions you may have regarding
TENO RM.
Thanks again!
George
{ieorge P. PartrU[ge Jr., Pfi'D, P.'E., Q'EP

. . . .nkfort, KY 40601
~2) 564-6716 ext. 4651
GP359
Curt Pendergrass's contact information within the DPH:

--
-----C--urt-PeAclergr-ass-Pl"ID--~--"- --

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Website: http:/(www.chfs.ky.gov/dph/radioactive.htm
Relevant Regulations Related to Issues Surrounding TEN ORM:
'
902 KAR 100:012. Fee schedule. http://www.lrc.state.kv.us/kar/902/100/012.htm

offense.
2
GP360
GP361
-m:
Sent:
To:
Subject:

'twilfong@republicservices.com'
FW: RE: Regulation of TENORM in Kentucky
Tim, I mistyped your address.

Sorry,
George
Sent: Friday, February 05, 2016 3:12 PM

To: 'bmcintyre@republicsevices.com'; 'twilfong@repblicservices.co'
Subject: RE: Regulation of TENORM in Kentucky
Hello Bill and Tim;
It was a pleasure meet you both yesterday at Green Valley and discuss the shipments of TENO RM that has been brought
to the attention of the Division of Waste Management that are being received from out of state .
. . .Rodney Maze and I shared with you, TE NORM is regulated by the DPH and the individual that stays in contact with
I have his contact information below. He is their
expert on TENORM. Curt and I have been corresponding the past several years and been concerned that eventually
TENO RM wastes would be shipped in violation of KRS 211.863. The regulations that have been emphasized related to
TENO RM by the DPH have been inserted below along with Curt's contact information.
r:i.r Division regarding radioactive materials/waste is Curt Pendergrass.
It is a pleasure to visit Republic Facilities and how conscientious your company is in seeing that everything is managed
well as illustrated by your facilities have calibrated detectors and all you do to manage the waste streams you receive.
Fortunately, we hope that any waste you have received is the low level TENORM and the TENORM waste that is at much
higher levels is being disposed further in the state at facilities that do not have detectors to screen incoming waste.
As we learn more how the shipments are being managed and disguised so the receiving facility will not recognize the
nature of the waste we will pass that information on to you as we continue to investigate this situation. We have
already identified individuals/companies involved in these illegal shipments and they are being investigated.
In closing, I want express our appreciation again to you both, that Rodney, Karen, and I could visit you and bring this
matter of concern to your attention. We appreciate all you are doing to support our efforts of curtailing receipt of this
TENORM waste.
As industry brings this to the attention of upper management in state government, that will encourage the development
of a regulatory and enforcement framework that will assure the safe management and disposal of TE NORM .
se do not hesitate to contact me if I can be of further assistance or help with questions you may have regarding
ORM.
..
Thanks again!
1
GP362
George
{jeorge P. Partridge Jr., Pfi'D, P.'.E., !2_'.EP

Frankfort, KY 40601
(502) 564-6.716 ext. 4651
Curt Pendergrass's contact information within the DPH:

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Relevant Regulations Related to Issues Surrounding TEN ORM:



2
GP363
ten t.housand dollars ($10,000) nor more than one hundred thousand dollars
offense.
GP364
~;m:
Sent:
Subject:
Microsoft Outlook
twilfong@republicservices.com
Relayed: FW: RE: Regulation of TE NORM in Kentucky
Delivery to these recipients or groups is complete, but no delivery notification was sent by the
destination server:
twilfong@republicservices.com (twilfong@republicservices.com)
Subject: FW: RE: Regulation of TENORM in Kentucky
GP365
--om:
To:
Sent:
Subject:
Wilfong, Timothy <TWilfong@republicservices.com>

Read: RE: Regulation of TENO RM in Kentucky
Your message
To:
Subject: RE: Regulation of TENORM in Kentucky
Sent: Friday, February 05, 2016 3:28:42 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Friday, February 05, 2016 3:28:38 PM (UTC-05:00) Eastern Time (US & Canada).
GP366
-om:
Sent:
To:
Subject:

Curt;
Thank you for sharing the latest correspondence and analytical results with me. I visited Green Valley LF yesterday with
representatives from our Morehead Regional Field Office (DWM) and confirmed they are receiving TENORM wastes
from out of state coordinated by Cory Hoskins. Another company name was listed which appears to be an LLC he has
also established in addition to Advanced TENORM Services.
On Wednesday of next week, George Weems from our Regional Field office and I will be making an unannounced site
visit to Blue Ridge LF where the waste from Fairmont Brine Products was disposed of by Advanced TENORM Services and
investigate how it was handled and managed which will allow me to develop a exposure scenario for risk assessment
calculations.
Cory Hoskins has misrepresented the technical capabilities and services that Advanced TENORM Services is capable of
providing. All he did was coordinate the disposal of this waste at a landfill in Kentucky.
,~~=-that legal action will be taken again him and also all those that were associated with this case of mismanaged
It was a pleasure to meet and join Chris Keffer yesterday for our site visit to West Liberty.
Please continue to stay in touch with me. It is my desire to support all that you and your group are doing to address this
concern and protect the future well-being of our landfills and all the associated management/operating personnel that
provide important services to our communities.
Thanks again,
George

To: Frame, Jason R
Cc: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); McKinley, Matthew W (CHS-PH); Anderson, Danny J
(EEC); Loyselle, Maridely (EEC); Webb, April (EEC)
..-..illr.elevated U-238 and Th-232 parents, is way over anyone's acceptable criteria for burying waste in anything but a
~rdous waste landfill specifically licensed for the disposal of radioactive material. Now that we know your office put a
1
GP367
much lower bid from Advanced TENO RM Services of West liberty, KY (http://advtenorm.com/ ) makes the company
how best to address this issue since the wastes is now buried at several municipal solid waste landfills here in KV. Again, .
1
we just can t thank you enough for all your assistance in this matter.
Curt
Fairmont Brine .. ~udge ~t Cl
Project
P~ Pfoi~ Nq,;
. 30,150~5~
Sample: FairmQnt Brint!'-Sludge Pit
Ci
~b to: 30150:255001
Collected: .Q$/08115 09:25
Reooiv~: ~1515:45
Mafl
Results reported on a "dtY~f1ht: basis
UnltS.
Pai:arooters
Arit~rtyaf24
EPAOOU
(1~000
C~t-00
EPAOOU
lridi!Jm-192
EPA001.1
POt~:sslJm416
:!:0.$74 (2J)37)
PCiig
OOJ1!,V1516:51 1.
~r: ;.~~ ti.3)
pCllg
00/1511516:51 11
0.000 0.634 (1.680}
pCi'Q
06/1611516:51 1
EPA001.1
26.6'ot'1Q.~6 (17,130)
pClfg
0011511516:51
Radium~
EPAOOU
c:lfAT:NA
1453..$00 ,i; ~{)0.78(1 (44.630}
J:iadium~
Scalldfum-46"
.$ilVeM10M
C~NAT;NA
c:NA 'f.NA
pCilg
OOJ15115 if>:S1 1 ' '
EPA901.1
c:HAliNA
3o3.7so :1.114
p(:lifg
0,6/1!,;,1516:~1
EPA001.1
l.268 1.78i4
(1.774)
pCilg
00t15!1516:61 1:
EPAOOU
CtNAT:NA
~.$J~1 t~.SQ (1~M9J
pCllg
IJ6/1511516:Q1 1
16:2:~1Mi*'392;1to
~Ilg
11511$16:51
pCitg
oo.i1511516:.51
1h6Jlll".232
EPA001.1
Ur.;inlum-233
EPA00.1.1
(7.811)
....
C~HAT:NA
cNA. T~NA
C~tf.i\T:NA
.94.33~ 17,406
C~NAT:NA
{478:{)()0}
. ..... .
(17.7~}

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
N.~
1:
. .. . . . ,. ..
1~.~U\TlrJrf.iMt:n1
2
GP368
1:
z.

~nt: Friday, February 05, 2016 11:10 AM
~: Pendergrass, Curt (CHFS DPH)


Charlestonr West Virginia 25301
Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
efl.nks again for all your assistance.
3
GP369

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Be notif~!:LQf_pJQJJOsgc:!rnKl.llatiQll ch;:in_ges https://secure. ke ntucky .gov /Reg""atch/ ..
-~
Sent: Friday, February OS, 2016 10: 18 AM

'

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
GP370

- l o Jason,
sludge. The West.Virginia Department of Environme

Environrnental Protection Agency (US EPA) ldentifica
can't seem to find anything on the web other.this blurb below which references 185 Bq/kg or 5 pCi/g above natural
to the actual WV regulation which references this TENORM limit for disposa.I in WV. I believe OH chose to use this 5
_.~g Ra-226 + Ra-228 plus daughter products as well as their limit for disposal in the regular waste stream.
_M
Just to let you know, while KY lacks specific regs addressing TENO RM, our Central Midwest Interstate Low-'Level Waste
Compact of which KY is a member along with IL, specifically prohibits the disposal of out-of-corn pact wastes here in KY.
.exempt from federal hazardous waste regulations under Subtitle C of the Resource Conservation and Recovery Act
Thanks,

5
GP371
(3) Naturally-occurring radioactive material (NORM) as defined in I<RS 211.862(8)

shall be the exclusive regulatoryresponsibility of the states, e,~ce,p1:Jhflt.rio person
sp,:~lljrpottnatur{llly occurringr~dio~ctive.materi~lC~98-M)rfrc,foi.9\itsidethe,
mf~~~~i~itz~~~}Jg~~!1J~~ti~.ti~{tif~s~uh;$s}l&~~t1Rf~-~~sf~ti~enJcky,
.. with-an~-administrativ~regulations-promulgated pursuant to KRS-21.1-.85.~tor . --~----211.865, or fails to comply with any order of the cabinet issued pursuant to KRS
offense.
radioactivit)' of ~?cks. or soi~s, or bac~gro~nd ra~iation~ .but i?st.ead t~feirs~tQ
~~t ~~~~st~~~~E~~i~~~I~~;fl{t.~~ltfl~l~gic;a1!y-etth~n9~&.$.Y"s.6ntfor1~~1t(~;Practices

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
..
a.,

6
GP372
Brine
attatchment

Office: (304)356A303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.
f
u could provide additional information related to our conversation about the shipments by Advanced TENORM
ices to Kentucky that would be helpful.
GP373

_J_~now some of the a!J_gy~ iterr:is_ w_~ <:fjs_q1_ssed irl_Q!li_fO_QY~!s_atiqri~!_ l_yva_s ~()_fl()p_r_~d-~i!~ ~_tie _!Jew~~ wat)!_tQp~_:;_u_r_e_J
George
(jeorge P. PartrUfne Jr., Pfi'D, P.'E., !2.,'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
8
GP374

To: Frame, Jason R
,lo Mr.
Frame,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky.gov Id ph/rad ioa ctive. htm
Dispose of unwanted _sources http://www.crcpd.org/StateServices/SCATR.aspx
GP375

Mr. Pendergrass,
_
_ operating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please
----advise on tlliSfssu-e.-Thanks-- -- -- -- - - ------- --------------------- --------------~-~-------------

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
Midwest Interstate Low Level Radioactive Waste Compact of which KY is a member'with IL. The compact strictly forbids
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this e- ~
Ai.._
10
GP376
is required .
.-ards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Dr. Pendergrass,
the "facking" sludge in Ashland, KY and then sending it to a Class D landfill in Irvine, KV. Mr. Fame's question was in

Frankfort, KY 40601
Ph: 502-564-3700 x4179
502 330-7662
: 502-564-1492
11
GP377
-m:
Sent:
To:
Subject:

RE: TENORM Environmental Monitoring
Lindsey;
Thanks for sharing the correspondence Todd is having with others regarding TENO RM with me.
George

Subject: FW: TENORM Environmental Monitoring
fyi

......_Anderson, Danny J (EEC); Briggs, Lindsey (EEC)
rject: TENORM Environmental Monitoring
Louanna,
Radium-226
Radium-228
Polonium-210
Lead-210
Radon - forms from the decay of radium; preferentially follows other gases, can end up in landfill gas, prefers ethane
and propane. Will eventually end up being released through the landfill or gas system into the air,
Groundwater: A landfill that has accepted TENO RM should already have a functioning groundwater monitoring system
it?red at least as often as the groundwater (i.e., quarterly) for the same list of parameters. Radon will probably not
n issue.
..
1
GP378
pathways.
Regards,
Todd

Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4653
GP379
-m:
Sent:
To:
Subject:

'Frame, Jason R'
Jason;
I visited the address of Advanced TENORM Services yesterday with representatives that Curt Pendergrass sent along
with representatives from our field office for the Division of Waste Management. We met with Cory Hoskins the
"President" of the company. He is it, there are not facilities, testing labs, team of experts, etc. - all he does is
subcontract what he needs. He said the waste was shipped from WV to the landfill in Kentucky and no testing or
treatment was done before the landfill received it.
He has misrepresented his company which is located in a small partitioned office area about the size of two office
cubicles on a floor in the Morgan County Public Library. The manifest and transport records he said he keeps at his
home.
To me his conduct is not only a violation of the Kentucky Revised Statues that regulated interstate commerce of
TENORM but also this is fraud regarding how he represented his company. I also feel that the transport company and
others that were part of this case of mismanaged TENO RM wastes should also be held accountable .
....la>preciate all you are doing to help us identify and track TENO RM wastes that is going to our landfills so we can protect
well-being of the landfills along with the managers/operators that provide important service to our communities.
'IJ'le
Please continue to keep in touch and copy me on correspondence. I will be continuing to investigate this situation and
support any initiative taken by the management of the Division of Waste Management to address TENO RM.
Thanks again,
George
(jeorge P. Partriclge Jr., Pfi1J, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
~:-Frame, Jason R [mailto:Jason.R.Frame@wv.gov]

GP380

??? page 24

- _ Qffice: {30Ll:l_l~().:-:4:}()~---"
Fax: (304) 558-0524

To: Frame, Jason R
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of u~wanted sources http://www.crcpd.org/StateServices/SCATR.aspx
VeJtfU
IV~.:~~~~"',_ ~
..
P.At!lATlOHJA:latUSM

2
GP381

__jfiect: RE: TNORM disposal in KY
W.se results were provided to me by Waste Management while they were involved with the project. The said this was a

Office: (304)356-4303
Fax: (304) 558-0524
~-
------------- --- ----------- ..................... ---------- ., ----

To: Frame, Jason R
..
. Republic Services operates many landfills here in KY and it is a company policy that all Republic landfills have drive
~East Main Street
~stop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
3
GP382
.rie.~
J:/....,......m.
~~~,.~re'-
f~J..1>\TlON..J.UaJtt;'lf!

senE:
Frra-ay, -February os>-2016 ra: 1s-,a.-rvr-0
'~-L----T---
---------------
-- - - - - - - - - - - - - - - - - -


Office: {304)356-4303
Fax: {304) 558-0524

To: Frame, Jason R
Hello Jason,
presume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID~;
number was the radioanalytical analysis of this wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on . _ ,
4
GP383

-rocessed FBP's Notification of Regulated Waste Activity Form. A!
Also, I remember seeing something in the lay press about WV issuing new regulations regardingTENORM. However, I
background. I am assuming FBP analyzed the loads in question and determined they exceeded this WV limit.Also, I am
pCi/g Ra-226 + Ra-228 plus daughter products as well as their limit for disposal in the regular waste stream .
..
See below. How that ties in with the EPA's determination that "Wastes generated during the exploration,developrnent,
radioanalytic data oh these loads from FBP that you could share with us, we would be extremely grateful.
Thanks,
Curt

(3) Naturally-occurring radioactive material (NORM) as defin.edinK~S.211.8.62(8)

~hall. be thee)(clusiye regulatory responsibility of the states, ~xp~gI{nifi~.~\f?~t~Jln
"'~"i"'""l,11~~~'~,~~l!~li!trt~ilf~:~~~

5
GP384
offense.
~---~

--~--r11dienuolide-00noentratiens-hav6-bn~inGn~asdby-Gr~,as-a-rtIBult-of-human--~-.--- -- --- ------- ---~~-----practices. Naturally occurring radioactive material does not include the natural
radi~acti'7ity ofroc,ksor s~i~s, ()rbac,kg!oun~ radiati9~, butinsteadt~~~r~to; . . -.-
~,t~w~~j~g~~l~\~~%~~%~twf~!;t~bMblog19a~Iyeti[~ii~_ed~y-b~~tf~U~1Jk;ptadti9eg
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492

Level of radioactivity. Exposure rates were be.tween 500 uR/hr and 2 mR/hr
Name of company in Fairmont along with County that contracted with Advanced TENORM.Services. Fairmont
Brine
attatchment
Jason R. Frame B.S. R. T,~ (R), Chief Radiological Health Program

6
GP385

~ce: (304)356-4303
~-: (304} 558-0524

To: Frame, Jason R
~ject: RE: TNORM disposal in KY
~on;
TENORM disposal.
As much detail as, possible will be helpful as we review manifests, etc. at the landfills.

Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent t~the landfill.
_ . , o u r Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
7
GP386
George
<george P. PartridjJe Jr., Pli'D, P.'E., Q_'EP

~H- ~~~n~f~~~~~s4~:~; 2nd Floor (SWB)_ ~_
(502) 564-6716 ext. 4651

Subject: FW: TNORM disposal
in KY

Office: (304)356A303
Fax: (304) 558-0524
GP387
...a
Frame, Jason R
~ McKinley, Matthew W (CHS-PH); Brock, Stephanie C (CHS-PH)
Hello Mr. Frame,

Hoski_ns, and ascertain the nature and extent of their activities. We will also reach out to our colleagues in the Energy
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
your fees on line at https:ljprd.chfs.ky.gov/rad epay/
~~otified of proposed regulation changes https:ljsecure.kentucky.gov/Regwatch/
Dispose of unwanted sources http:f/www.crcpd.org/StateServices/SCATR.aspx
,.,a
To:

Mr. Pendergrass,
Jason R. Frame B.S. ,R. T. (R), Chief Radiological Health Program


..a..ee: (304)356-4303
~ {304) 558-0524
GP388
Sent: Tuesday, July 21,

To: Frame, Jason R
2015 9:45 PM

Hello Mr. Frame,
the disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously , . . .
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
intended recipient, be advised that you have. received this e-mail in error and
herein.
10
GP389

: jason.r.frame@wv.gov
Dr. Pendergrass,
https:ljapp.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
999 ). From Mr. Frames understanding, Advanced TENORM Services L.l.C. (located in West Liberty, KY) will be solidifying
back to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TN ORM
Radioactive Materials. Section
Frankfort, KY 40601
Ph: 502-564-3700 x4179
~: 502 330-7662
r~.~= 502-564-1492
cont<!in confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
11
GP390

.
m:
Sent:
To:
Subject:

Curt;
Please help me understand what you meant by the statement "digging up dirt" here in KY.
Also please share the importance of what is missing in the analyses so I can understand this situation better since I am a
chemical engineer and my background has been with hazardous chemicals, not radioactive materials.
I am delighted that we continue to correspond and share notes, etc. since it has expanded my understanding of this
important area of waste management.
George

nt: Friday, February 05, 2016 12:06 PM
Frame, Jason R
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
E-mail: curt.pendergrass@ky;gov
Be notified of proposed regulation changes https:l/secure.kentucky.gov/Regwatch/
Dispose of unwanted sources http:l/www.crcpd.org/StateServices/SCATR.aspx
/(f_
~~Fr~~;~]~~~n R [mailto:Jason.R.Frame@wv.gov]
1
GP391
,A...
These results were provided to me by Waste Management while they were involved with the project. The said this was
...,.,

- _Charleston,JNest Virginia2.5.3Q1_
Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
..
2
GP392
your fees on line at https://prd.chfs.ky.gov/rad epay/
~notified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
...JJiJl
V.nn~~
re..~ilJJ . . .
t'.AtlJ;;\110NA\t-l:IWJ..'f.H


Jason R. Frame
B.~.
R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: {304) 558-0524
"'ail: Jason.R.Frame@WV.gov
To: Frame, Jason R

Hello Jason,
, ~m for actual data. on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughte. r products? I would
ume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
3
GP393

processed FBP's Notification of Regulated Waste Activity Form_. Attl
Environmental Protection Agency (US EPA) ldentiflcatio,n Number
. baGkgr:oundAam...assuming-J;BP-analyzed-theJoadsJnquestion.andde.teunjned_th_ey_excee.de~d..thlS.W\lJLrniLAlsQ,_1_.anL_~_
Thanks,
Curt

shall be. the exclusive regulator res onsibility of the states, ~~ci~p,t;tJ1~fppp~f~6I}"
~Iii~~~;;,~=~,.
"'~ilttltlilr1ilf~~q~y;

4
GP394

offense.

practices. Naturally occurring radioactive material does not includet~e.riatural
radioactivityofr?cks or soils,or background racliation, but instea4: ife~s.tq
~fi~~l~]~t~~~~~~~~~~~w1~~t~gW\Ql2g!~nY ~l1.h~n.deqlJyc~11ttql!~~i~1Iig~tr~~

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
mail: curt.pendergrass@ky.gov
.
y your fees on line at https://prd.chfs.ky.gov/rad epay/
Be notified ofproposed regulation changes https://secure.kentucky.gov/Regwatch/
~Jr'~.~
ffJJ;>IATitfH&.ff~TH

T~: Partridge, George (EEC)
I-
Dates and time period the shipments were.sent. Shipments occurred during August 2015 .
Brine
attatchment

5
GP395

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.

Name of company in Fairmont along with County that cohtracted with Advanced TENO RM Services.
I know some of the above items we discussed in our conversation but I was so floored with the news I waht to be sure I
6
GP396
- - k forward to hearing from you!
George
(ieorge P. PartridiJe Jr., Pfi1J, P.'E., Q'EP

Frankfort, KY 40601
(502) 564~6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
GP397

To: Frame, Jason R

Hello Mr. Frame,
TENORMServices of Liberty, KY (http://advtenorm.com/ ). We will follow up with the company's president, Cory
---- Hoskins,
the nature and
of the-ir actiVitieS~We w-n1aTso rea-ChOUt-tO our colleag~Ues Tri-the Erl'ergy---
andasc-e-rtain
extent-
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~"
Sent: Tuesday, January 191 2016 12:51 PM


Mr. Pendergrass,
operating as" Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524
GP398
------- ----

To: Frame, Jason R
Hello Mr. Frame,
.
dwest Interstate Low Level Radioactive Waste Compact of which KY is a member with IL. The compact strictly forbids
udes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
lying to this message and delete this e-mail immediately. Nothing in this
unication, either written or implied, constitutes or should be construed as a
egally binding agreement between the parties with respect to the subject matter
herein.
GP399

Dr. Pendergrass,
--~~us1 ng tneserviC:es~provide-ctor~dva-n-ce-d-1cNORMS-ervice~tL.C: (- ~ ---~-~~---~-
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFl.DENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
10
GP400
&..
...
-m:
Sent:
To:
Subject:

Curt;
Thanks for sharing this with me! I look forward to learning what Jason's response is to your question. My understanding
is the waste that are being exempt that you question Jason about include important sources of TENORM.
Thanks again,
George

To: Frame, Jason R
Thanks Jason. Do you know why WV chose to exempt "wastes generated during the completion process or derived from
~hydraulic fracturing process, including but not limited to, flowback solids and liquids, brine, tank bottoms, pit
~anout material and sludges, filters and filter media, pipe scale, used frack sand and proppants, etc."? Was that due to
industry pushback? I believe OH also issued a broad exemption in its TENORM regulations as well but those applied
strictly to oil and gas production operations in OH and not those from out-of-state.
https://www .odh.ohio.gov1~/media/ODH/ASSETS/Files/rules/final/3701 1/37011-43/37011-43-07 .pdf I doubt WV
would allow a company from KY to bring these same wastes produced in KY into your state for disposal.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Pay your fees on line at https://prd.chfs.ky.gov/rad epayL
Venftifl;~~'
1v_,,....,...._'.:;;'::!f
ft.,.'i.t.llATloti2',MlZtd..'ii'!
!
e!f;~F;~rn;;. .J~"~~~R[~ailto:Jason.R.Frame@wv.gov]
1
GP401

http://apps.sos.wv.gov/adlaw/csr/ruleview.aspx?document=9530
5.6.a.1. "Drill Cuttings and Associated Drilling Wastes" means the broken bits of solid material and drilling mud removed
from a borehole drilled by rotary, percussion, or auger methods, but does not include wastes generated during the
completion process or derived from the hydraulic fracturing process, including but not limited to, flowback solids and
liquids, brine, tank bottoms, pit cleanout material and sludges, filters and filter media, pipe scale, used track sand and
proppants, etc.
5.6.d. Radiation Monitoring

5.6.d.1. All Solid Waste Facilities that accept drill cuttings and associated drilling waste for disposal must
install fixed radiation detection equipment at the entrance to the facility. All drill cuttings and associated drilling wastes
generated in the exploration, production and development of oil and natural gas and associated activities must be
evaluated by this equipment. The facility must also have a portable radiation monitor capable of determining dose rate
and the presence of contamination on a vehicle. The facility shall provide staff with documented training in the
operation of all onsite radiation monitors.
5.6.d.2. The fixed detector must be capable of measuring exposure rates from ten microroentgens per hour
(10 R/hr) to greater than fifty milliroentgens per hour (>50 mR/hr.). The instrument must be maintained and calibrated
according to manufacturer specifications.
5.6.d.2. The detector elements must be configured to be as close as practical to the waste load and in
appropriate geometry to monitor the waste.
aL
'W
5.6.d.3. The facility shall set the detector to sound an alarm if the reading on the detector exceeds
10R/hr.abovelocalbackground.
5.6.d.4. If a load of drilling cuttings or associated drilling waste is confirmed to be less than ten
microroentgens per hour (10 R/hr.) above local background level, the waste may be disposed of in the facility. If the
load of waste is confirmed to be equal to or greater than 10 R/hr. above local background level, the combined
concentration of Radium 226 and Radium 228 must be determined. The combined concentration must be analyzed by a
State approved method. If the combined concentration in the waste is less than five picocuries per gram (5pCi/gr.)
above local background level, the waste may be disposed in the facility. If the values are greater than 5pCi/gr. above
local background level, the load must be rejected.
5.6.d.5. For each radiation alarm generated the facility shall provide an incident report to both the West
Virginia Department of Environmental Protection (DEP) and West Virginia Department of Health and Human Resources
(DHHR) Radiological Health Program using Form 1W Solid Waste Radioactivity Reporting Form within 24 hours of the
initial alarm. Form 1W can be obtained by contacting the DHHR Radiological Health Program.
5.6.d.6. Solid Waste facilities accepting drill cuttings and associated wastes must submit and obtain
approval from both the DEP and the DHHR Radiological Health Program of a Radiation Monitoring Plan that outlines the
facility's procedures for managing the waste.
illri....
5.6.e. A commercial solid waste facility located in a county that is, in whole or in part, within a karst region
determined by the West Virginia Geologic and Economic Survey, may not accept drill cuttings and drilling was. .
generated from horizontal well sites.
GP402
-...son R. Frame B.S. R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524

nt: Friday, February 05, 2016 10:36 AM
Frame, Jason R
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
502-564-1492
ail:
. . curt.pendergrass@ky.gov
3
GP403

ac.
vmtu. ;~
1V.~,.~11UJ,_~2
f1J1;tilATJ0f'l AH!lt'J:TH

subject:~Ri::~'fNORMdisposal"iffKY - - --- - -WV DEP is not involved in any type of radiological permitting. I believe you are referring to the drill cuttings disposal regs

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Jason,
GP404

: . .rocessed FBP's Notification of Regulated Waste Activity Form. A!
Also, I remember seeing something in the lay press about WV issuing new regulatiqns regarding TENO RM. However, I
Thanks,
Curt

(3) Naturally-occurring radioactive material (NORM) as defined in !(RS 211.862(8)
sh~llb~ t?~~x~lusiv~ regl1latory r.7s]Jonsibility ?f .t~e states, ~~~~P;.t:on~f'il6p~[~9n
ffli't~1~1lt-t~ll&il~~~~fi!!lf;~lt~4.YJ

5
GP405
offense.
- -~---radionuelide-oeneentr-ations-havs-been-inornasefl-by-or-as a-result-of~human--- practices. Naturally occurring radioactive material does not includethe~atural
radio~ctivity.ofrocksorsoils, or~ackgroundradiation, ~ut i?steadr~forsito:. _ ...._._
~~ttii~~~t~~/~}~~4~~~~~-i~f~c~n~lgiq~ly/enhance4_by6ontre>llabJ~-.prigtices;

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
........
r;k'>

Brine
attatchment
..

6
GP406

~ce:
~:
(304)356-4303
(304) 558-0524

To: Frame, Jason R
...jl>ject: RE: TNORM disposal in KY
-.:on;
TENORM disposal.

confirmed the understanding we have of the situation before we move forward with site visits .
. -our Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
7
GP407
George
(jeorge P. Partric{ge Jr., Pli'D, P.'E., Q'EP

-~--200-Eair~Oaks-Lane ;...2ndJ:::ioor:-~SWB}--~
Frankfort,
KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
GP408

Frame, Jason R
Hello Mr. Frame,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
your fees on line at https://prd.chfs.ky.gov/rad epay/
,_9
-~... ~otified of proposed regulation changes https:ljsecure.kentucky.gov/Regwatch/

~

Subject: RE: Ti\IORM disposai in KY
Mr. Pendergrass,

9-:e: (304)356-4303
.Fax: (304) 558-0524
GP409

To: Frame, Jason R
Hello Mr. Frame,
the disposal of any and all radioactive materials generated outside of IL and KY anywhere. in our states. This obviously
contaminated waste so Advanced TENORM Services might want to check with the authorities in those statesto see what
is required.
&..
W
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
10
GP410


Dr. Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
_ . : 502 330-7662
C~.~: 502-564-1492
11
GP411
-m:
Sent:
To:
Subject:

Friday, Februa~ry 05, 2016 5:07 PM
'Frame, Jason R'
Jason;
Thanks for sharing the analytical results with our Solid Waste Section in the Division of Waste Management. We will be
investigating the landfill where the waste was disposed of and these analytical results will be helpful.
George Partridge
KDWM



Office: {304)356-4303
Fax: {304) 558-0524

Frame, Jason R
c: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)
GP412
actual radiochemical data on the loads in questions would be extremely helpful. Does WV actually make companies like&...
~
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Website: http:Uwww.chfs.ky.gov/dph/radioactive.htm
J(.epJJ!~)
PJ\Dl,'.\TIUf'~ ~t1~\l.TH


Office: (304)356-4303
Fax: (304) 558-0524
GP413

To: Frame, Jason R
Sent:
Hello Jason,
'51udge. The West Virginia Department of Environment81 Ptoteetio

GP414
See below. How that ties in with the EPA's determination that "Wastes generated during the exploration, development,&...
~
(RCRA)" will be question for my colleagues in the Energy and Environment Cabinet to answer. But if you attual
Thanks,
Curt_
shall be t~e exclusive regulatoryresp?nsibility.of the stat~s, e~pepfthat.npp~rs}:>#
r;~1ri~f~~~~~iilDiill~~~~~~lt!~~~~~t~!fu;ky.

211.865, or fails to comply with any order ofthe cabinet issued pursuant to KRS
offense.
radio~c.tivity o~ r?cks ors oils, bac~g~ound radiatio11, but instead rM~I"s 1a
?r
~;~;f~~~fff~:~(~~~~f~~li~ ii?ieshri~!~l~ts~i,1y.ert,~I1y~~by.pq*tf9lJa~1~ pract19~~

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http:Uwww.chfs.ky.gov/dph/radioactive.htm
4
GP415
Be notified of proposed regulation changes https:/fsecure.kentucky.gov/Regwatch/

'~'

Brine
attatchment

ce of Environmental Health Services/Radiation, Toxics and Indoor Air Division
rleston, West Virginia 25301
Office: (304)356-4303
Fax: (304) 558-0524

t: Friday, January 29, 2016 3:48 PM
Frame, Jason R
ef
GP416
Jason;
I will be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding. . .
TENORM disposal.
~

George
(jeorge 'P. 'Partridge Jr., 'Pfi:D, 'P/E., Q:E'P

Frankfort, KY 40601
(502) 564-6716 ext. 4651

GP417

_..Aice of. Environmental Health Services/Radiation, Toxics and Indoor Air Division
F ' O Capitol Street, Room 313

Office: (304)356-4303
Fax: (304) 558-0524
m:
Pendergrass, Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]
t: Tuesday, January 19, 2016 4:33 PM

Frame, Jason R
Hello Mr. Frame,
TENORM Services of Liberty, KY (http:/(advtenorm.com/ ). We will follow up with the company's president, Cory
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
..-.site: http://www.chfs.ky.gov/dph/radioactive.htm
~your fees on line at https://prd.chfs.ky.gov/rad epay/
7
GP418

- - --
---------------------------------
------~--~-----~----------~---
Mr. Pendergrass,
Jason R. Frame B.S. R.T. (Rj, Chief Radioiogicai Health Program

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,
While KY does not currently have any regulations dealing with the control and disposal of NORM[fENORM waste
generated in the oil and gas industry from hydraulic fracturing, we do have statutes on the books estab-li-shin_g the Centra'ttl
1
includes tracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM[fENORM in landfills here in KY is their
8
GP419
~equired.
tlJRegards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
prohibited. If you have received this .e-mail in error, please notify the sender
herein.
---------
..-----~--
---~--------~~"--~-~--.~~~-~-~~----~---~--~-"'------------~~--~---

: Tuesday, July 21, 2015 1:19 PM
Cc: jason .r .frame@wv.gov
Dr. Pendergrass,

Frankfort, KY 40601
~ 502-564-3700 x4179
~: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure und13r applicable law. If the reader of this message is not the intended recipient, you are notified that any
GP420
Subject:
Attachments:

Lindsey;
Waste analytical results for the shipment of wastes from WV to Blue Ridge Landfill.
George
From: Frame, Jason R [mailto:Jason.R.Frarne@wv.gov]


~son R. Frame B.S. R. T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
Email: Jason.R.Frarne@WV.gov
! . .
GP421

Turner, Tony
Cc:
Subject:
Glad to provide any help we can. Thanks
Sent via the Samsung Galaxy N{Jtc
~,an
AT&T 4G I.TE s1rnwphone
-------- Original message -------From: "Partridge, George (EEC)" <George.Partridge@ky.gov>

Date:02/05/2016 4:57 PM (GMT-05:00)
To: "Frame, Jason R" <Jason.R.Frame@wv.gov>
Cc:
Jason;
I visited the address of Advanced TENORM Services yesterday with representatives that Curt Pendergrass sent
along with representatives from our field office for the Division of Waste Management. We met with Cory
Hoskins the "President" of the company. He is it, there are not facilities, testing labs, team of experts, etc. - all
he does is subcontract what he needs. He said the waste was shipped from WV to the landfill in Kentucky and
no testing or treatment was done before the landfill received it.
He has misrepresented his company which is located in a small partitioned office area about the size of two
office cubicles on a floor 'in the Morgan County Public Library. The manifest and transport records he said he
keeps at his home.
To me his conduct is not only a violation of the Kentucky Revised Statues that regulated interstate commerce of
TENORM but also this is fraud regarding how he represented his company. I also feel that the transpmt
company and others that were part of this case of mismanaged TENORM wastes should also be held
accountable.
~ppreciate
all you are doing to help us identify and track TENORM wastes that is going to our landfills so we
can protect the well-being of the landfills along with the managers/operators that provide important service to
our communities.
1
GP422
Please continue to keep in touch and copy me on correspondence. I will be continuing to investigate this
situation and support any initiative taken by the management of the Division of Waste Management to address . . .
TENORM.
Thanks again,
George
eorge P. Partridge Jr., Pli1J, P.'E., Q'EP

Frankfort, KY 40601
'
(502) 564-6716 ext. 4651

??? page 24
GP423

, i c e of Environmental Health Services/Radiation, Toxics and Indoor Air Division
Office: (304 )356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Thanks Jason. Unfortunately, the analysis of the FBP wastes by Pace Analytical appears to be devoid of
radioisotopic analysis, or even total radium. Looks like we may be digging up dirt here in KY.

, t u c k y Radiation Health Branch
3
GP424
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492

These results were provided to me by Waste Management while they were involved with the project. The said
this was a combined average of the loads, but I did not specify the sampling methods so can't speak too that.

Office: (304)356-4303
Fax: (304) 558-0524
4
GP425

To: Frame, Jason R
hanks Jason. That is exactly what I was hoping to hear. A WV regulation referencing a drive through radiation
rtal alarm of 2X background and 5 pCi/g Ra-226/228 above background, would be great if you can send me a
nk. Also, actual radiochemical data on the loads in questions would be extremely helpful. Does WV actually
make companies like Fairmont Brine conduct radiological surveys and radiochemical analysis of oil and gas
production fluids? I know that Republic Services operates many landfills here in KY and it is a company policy
that all Republic landfills have drive through radiation portal monitors. We get our share of alarms for medical
wastes in sewage sludge, usually long-lived isotopes such as I-131 which has a 8 day half-life. We even had a .
Republic landfill outside Ashland KY get a medical isotope alarm in a waste load from Huntington, WV not too
long ago. That load was found to contain Tc-99m which meant that with a 6 hour half-life, the wastes was pretty
fresh.

. . East Main Street
Mailstop HS 1C-A
5
GP426
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492



WV DEP is not involved in any type of radiological permitting. I believe you are referring to the drill cuttings
disposal regs that we developed with WVDEP which set gate alarms of 2x background and then 5 pCi/g radium
226/228 above local background analytical limits. I may already have data for the loads. Will check.
Jason R. Frame S.S. R.T. (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
GP427

To: Frame, Jason R
Hello Jason,
"1ave huge favor to ask of you. ls there any way that you can contact Fairmont Brine Processing in Fainnont
WV and ask them for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus
daughter products? I would presume the driving force behind FBP notifying your office of a regulated waste
activity and being assigned a US EPA ID number was the radioanalytical analysis of this wastes and not the fact
the wastes read 0.5-2.0 mR/hr, I presume on contact with the waste containers.

processed FBP's Notification of Regulated Waste Activity Fotm. A!
Also, I remember seeing something in the lay press about WV issuing new regulations regarding TENORM.
However, I can't seem to find anything on the web other this blurb below which references 185 Bq/kg or 5
pCi/g above natural background. I am assuming FBP analyzed the loads in question and determined they
exceeded this WV limit. Also, I am assuming this limit is based on protecting public and health and safety of
the citizens of WV but what I saw seemed to be more of a proposed rule and not an actual regulation
(http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping that you can share
or a link to the actual WV regulation which references this TENORM limit for disposal in WV. I believe
~chose to use this 5 pCi/g Ra-226 + Ra-228 plus daughter products as well as their limit for disposal in the
regular waste stream.
..8Y
GP428
Just to let you know, while KY lacks specific regs addressing TENORM, our Central Midwest Interstate LowLevel Waste Compact of which KY is a member along with IL, specifically prohibits the disposal of out-ofcompact wastes here in KY. See below. How that ties in with the EPA's determination that "Wastes generated
during the exploration, development, and production of crude oil, natural gas, and geothermal energy are
categorized by EPA as "special wastes" and are exempt from federal hazardous waste regulations under Subtitle
C of the Resource Conservation and Recovery Act (RCRA)" will be question for my colleagues in the Energy
and Environment Cabinet to answer. But if you actual radioanalytic data on these loads from FBP that you
could share with us, we would be extremely grateful.
Thanks,
Curt


shall be the exclusive regulatory responsibility of the states, ~}iq~pfI~f!t;UQ":~fsgn1
~~tll!~m~~tt1K~~~t~1f~~~~~i~~i~~~~~~1~~~,qi~i~f~~f1N~EM5Jtqtn~~~t:~X4~'~H~
t~g~:~11J~t~tf~xil?t~1,1i~~1iJ~Wii~FE~!~n~;~~'~t,~4li:1~m~rr~~!i!i"~~~t!~tr~11;i~&i~q~:1
l~111g~"1XnQ~tt~:Inr~,[f~t1m7:;~~:~~~~6t~i~t~~t~\Ylifi7~Qlfg~s~~r~u~'rs~fils:~i'fi~-

8
GP429

offense.


radioactivity of rocks or soils, or background radiation, but instead [~fet~
tp
m~tttI~1.\Yli9~eit~~~!fa~g!H~fii~~,,t~~IIB~19gigafly.enHafic~<l ~y;c:9~tr8na~1~ntac#~~~
c~1";;SM$~~{'tuiit~'Pi~~i!sg~)~

Mailstop HSlC-A
~ort, KY 40621
Tel: 502-564-3700 ext. 4183
9
GP430
Fax: 502-564-1492
..
E-mail: curt. pendergrass@ky.gov


Cc: Pendergrass, Curt {CHFS DPH)
The form or appearance of the waste when it was shipped (before solidification). What does it look like? Varied
but typically a brown sludge, with a water layer on top.
Level of radioactivity. Exposure rates were between 500 uR/hr and 2 mRJhr
Name of company in Fairmont along with County that contracted with Advanced TEN ORM Services. Fairmont
Brine
.
attatchment
Jason R. Frame S.S. R.T. (R), Chief Radiological Health Program

10
GP431

~~ice: (304)356-4303
Fax: (304) 558-0524

,

To: Frame, Jason R
Jason;
I will be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns
regarding TENORM disposal.
If you could provide additional information related to our conversation about the shipments by Advanced
TENORM Services to Kentucky that would be helpful.
~much
detail as possible will be helpful as we review manifests, etc. at the landfills.
11
GP432
..

I know some of the above items we discussed in our conversation but I was so floored with the news I want to
be sure I confirmed the understanding we have of the situation before we move forward with site visits.
Also our Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch. '
Thanks again for all the time you devoted to con-esponding and following up with us.
George
<]eorge 'P. 'PartridiJe Jr., 'PliV, 'P.'E., Q'E'P

12
GP433
Frankfort, KY 40601
" 2 ) 564-6716 ext. 4651

,
Office: (304 )356-4303
Fax: (304) 558-0524
..
13
GP434

To: Frame, Jason R
Hello Mr. Frame,
Thank you for the follow-up e-mail on the purported disposition of WV TENORM wastes here in KY by
Advanced TENORM Services of Liberty, KY (http://advtenorm.com/ ). We will follow up with the company's
president, Cory Hoskins, and asce1tain the nature and extent of their activities. We will also reach out to our
colleagues in the Energy and Environment Cabinet Division of Waste Management since they regulate landfills
here in KY.

Mailstop HS 1C-A
14
GP435
Frankfort, KY 40621
502-564-3700 ext. 4183

Fax: 502-564-1492


':"'ebb, April (EEC); ~eorge.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Sub1ect: RE: TNORM disposal in KY
Mr. Pendergrass,
I apologize for digging up this old email, but I don't believe I received any further response. I believe a
company operating as "Advanced TENORM Services" is continuing to facilitate the disposal of WV waste in
KY landfills. Please advise on this issue. Thanks

e!:.leston, West Virginia 25301

Office: (304)356-4303
15
GP436
Fax: (304) 558-0524
..

To: Frame, Jason R
Cc: Webb, April (EEC); George~Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Hello Mr. Frame,

is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
16
GP437
ressee(s) and. its content is confidential and privileged. If you are not the
nded recipient or the person responsible for delivering the e-mail to the
ended recipient, be advised that you have received this e-mail in error and
herein.

Dr. Pendergrass,
I was contacted this morning by Mr. Jason R. Frame; a member of the West Virginia radiation
program. He was inquiring about a West Virginia company's intent to dispose of TNORM from a "fracking"
operation here in Kentucky by using the services provided by Advanced TENORM Services L.L.C. (
https://app.sos.ky.gov/ftshow/(S(30yqolkfdaebcz4hporeemp4))1default.aspx?path=ftsearch&id=0904260&ct=O
cs=99999 ). From Mr. Frames understanding, Advanced TENORM Services L.L.C. (located in West
erty, KY) will be solidifying the "facking" sludge in Ashland, KY and then sending it to a Class D landfill in
vine, KY. Mr. Fame's question was in regards to whether or not we would allow the disposal ofTMORN
from other states in the state of Kentucky or send it back to the materials origins. I informed Mr. Frame that our
office does not currently have regulation regarding TNORM in place and that each landfill may have their own
limits on what they except or turn away in regards to radiation levels.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
CE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
in confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
w, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
17
GP438
-m:
Sent:
To:
Subject:

Maze, Rodney (EEC)
RE: Green Valley
Rodney;
Thank you! I would like to make a site visit to Pressure Tech and Big Run. George Weems and I plan to make a visit to
Blue Ridge on Wednesday of next week.
Let me know you thoughts on making visits to facilities in your region.
Thanks again for the opportunity to join you and Karen yesterday and all you did.
George

Subject: Fwd: Green Valley
,ached is the Tenorm waste documentation from Green Valley Landfill we obtained yesterday during the site visit
Rodney Maze

To: "Maze, Rodney {EEC)" <Rodney.Maze@ky.gov>

Morehead Regional Office
Divs ion of Waste Management
5 2 5 Hecks Plaza Drive
Morehead, KY 40351
606-783-8655
GP439
-m:
'

RE: TENORM in KY
Sent:
To:
Subject:
Curt;
Thank you for sharing this correspondence. You clearly indicated where in the regulations NORM is used and defined as
it relates to TENORM.
It is the applicant's responsibility to familiarize t.hemselves with the regulations.
Also, talking with Cory, he appears knowledgeable of the regulations in Ohio and WV and has studied the regulations.
He has misrepresented his company to clients. When I asked him about his website he told us it was done awhile back
when they were getting started up and he did not keep up with it. If you go to the web site, there is a "Copyright 2016
design 53" on the bottom of the pages which I thought referenced when the site was last updated.
Thanks again for continuing to share insights into this situation!
orge
.. ~ .. ~' ~~,,~_,_,,, ~> "'~"'"'"'=Ww' ""~""'"'~'~""
'
'""'=w ~"~""' '"~"-"'"'"'
-d
om: Pendergrass, Curt (CHFS DPH)

To: Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH); Partridge, George (EEC)
Subject: FW: TENORM in KY
Hello gentlemen,
Looks like I had telephone conversation with Mr. Cory Hawkins, Managing Member of Advanced TENORM Services LLC
would encompass TENO RM produced as a result of oil and gas exploration and production. Looking back on our
conversation, I wish I had also informed him in writing of the fact the compact forbid the disposal of out of compact
wastes here in KY and if such waste were disposed, penalties could be assessed. But as they say, ignorance of the law in
no excuse.


1
GP440

offense.
------~Kent1;1ek-y-Rac;liat~en-Health~ranel"l - - --- --~ - -- - - --275 East Main Street
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
'
To: 'Cory Hoskins'

Hello Cory,
It was a pleasure speaking with you this morning regarding the disposal of TE NORM contaminated wastes from the oil
and natural gas industries. Until you called, I was not even aware that your company, Advanced TENO RM Services, LLC
existed much less was headquartered in Ashland, KY. Looking ~t the KY Secretary of State's Office it appears you and
Solid Wastes and Hazardous Waste ever get around to drafting some TENO RM regulations for our cabinets and are
reaching out to the public and stakeholders for comment, we will most definitely be contacting you. Attached is a copy
of the KY Regulatory Statute dealing with the Central Midwest Interstate Low-Level Radioactive Waste Compact signed
between KY and IL. See http://www.lrc.ky.gov/statutes/statute.aspx?id=8498 or the CMC website at
(http://www.cmcompact.org/statutes/KRS%20211.862%20Definitions%20for%20KRS%20211.862%20to%20211~69.pdf
):
'
'
(8) "Naturally-occurring radioactive material... (NORM) means naturally occurring materials not regulated under
the Atomic Energy Act of 1954, as amended, whose radionuclide concentrations have been increased by or as a
Obviously this definition would encompass TENO RM produced as a result of oil and gas exploration and production.
2
GP441
Regards,
flll!::
Pendergrass PhD

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
GP442

'Frame, Jason R'
Subject:
Jason;
Thanks again for all the helpful information you are sharing with our Division of Waste Management. This will be helpful
as we move forward addressing TENORM.
Have a nice week!
George
To:

we developed with WVDEP which set gate alarms of 2x background and then 5 pCi/g radium 226/228 above local
. . .ackground analytical limits. I may already have data for the loads. Will check.
.Jt
Jason R. Frame
B~S.
R.T. (R), Chief Radiological Health Program
Office of Env.ironmental Health Services/Radiation, Toxics and Indoor Air Division

Office: (304)356~4303
Fax: (304) 558-'0524
GP443

'
Hello Jason,
sludge!' The West Virginia Department of Environmental Protectio

{http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping that you can share copy or a
'
Compact of which KY is a member along with IL, specifically prohibits the disposal of out-of-compact wastes here in KV.
{RCRA)" will be question for my colleagues in the Energy and Environment Cabinet to answer. But if you actual
Thanks,
Curt

2
GP444

with any administrative regulati9ns promulgated pursuant to KRS 211.859 or
offense.
211.862 Definitions for KRS 211.861to211.869.
radi?(lCti.vi~yofrocks .ors?ilS, ?r ba.c~ground radiation, b.ut instead tefets~t(j
Wl!t~~i@.iw-OQ~~rifc1i9act1Y:iiy~is te6IiTIC)1cfait)A!lY.~nhal,lced by .controllap~~.practi~es
(pr ~y'jJ~siJ:it1111a11 practic;e~1:i
tl:..rt
Pendergrass PhD
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492


N umber and type of trucks/ volume, etc. of the wastes. 35 vac boxes, unsure of volume but tractor trailersize.
GP445
Brine
attatchment
&..
W
-~~ason ..R .f.rame.B.S .. R.-T.. .(R)rChiefRadiological.HealthJ~.rogram

Office: (304)356-4303
Fax: (304) 558-0524
'
To: Frame, Jason R
Jason;
TENORM disposal.

4
GP446
George
<;jeor9e P. Partridjje Jr., Pfi1J, P.~., ftEP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
.-
GP447

To: Frame, Jason R

Hello Mr. Frame,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of unwanted sources httb://www.crcpd.org/StateServices/SCATR.aspx


6
GP448
'
Mr. Pendergrass,
~ologize for digging up this old email, but I don't believe I received any further response. I believe a company
~-~rating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
is required.
Regards,
Pendergrass, Ph.D.
rvisor, Radioactive Materials Section
ation Health Branch
Mailstop HS1C-A
7
GP449
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
__ prohibited. If OU have received this~e.:maiU11~rror,_r:>lease_11q_tify the sender~
herein.

Dr. Pendergrass,
htt s: a .sos.k . av ftshow S 30 olkfdaebcz4h oreem 4 default.as x? ath=ftsearch&id=0904260&ct=06&cs=9
999 ). From Mr. Frames understanding, Advanced TENORM ServicesLL.C. (located in West Liberty, KY) will be solidifying
the "facking" sludge in Ashland, KY and then sending it to a Class D landfill in Irvine, KY. Mr. Fame;s question was in
275 East Mai_n Street, HS1 CA
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable law. If the re_ader of this message is not the intended recipient, you are notified that any
GP450
e'am: .
Sent:
To:
Subject:
Attachments:

Todd;
We have some analytical results for the waste that was sent to Blue Ridge from West Virginia. This results will help up
identify constituents that should be monitored for in TENORM wastes.
Hope you will find this information helpful.
Look forward to us sharing with each other as we learn more.
I will be visiting Blue Ridge on Wednesday of next week with George Weems to investigate the situation in more detail.
Hope the week goes well for you!
Thanks again,
Sent: Friday, February OS, 2016 10:1S AM

FYI

Louanna,
Radium-226
Radium-228
Polonium-210
Lead-210
~~n -forms from the decay of radium; preferentially follows other gases, can end up in landfill gas, prefers ethane
~~ropane. Will eventually end up being released through the landfill or gas system into the air,
GP451
Groundwater: A landfill that has accepted TENORM should already have a functioning groundwater monitoring system '
--~ __ _he__an issue-'~ --~------C~ _______ _
pathways.
Regards,
Todd
'

Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4653
GP452
elm:
Sent:
To:
Subject:

RE: RE: Advanced TENORM Services
Curt;
I hope legal action is taken to have Cory's company responsible for remediation of the contamination in the landfills he
is responsible for.
Please keep me informed of any legal action that is taking place.
I appreciate so much we have kept in touch through the years and look forward to us meeting in person, which I
anticipate may be soon with all the TENORM disposal concerns we are addressing.
Thanks again for all you are doing.
George

nt: Friday, February 05, 2016 10:14 AM
bject: RE: RE: Advanced TENORM Services
According to the company's filings with the KY Secretary of State, Cory Hawkins is the managing member of Advanced
TENORM Services LLC and his wife is the organizer (https://app.sos.ky.gov/corpscans/60/0904260-06-99999-20150819ARA-6281199-PU.pdf and https://app.sos.ky.gov/corpscans/60/0904260-06-99999-20141208-AOG-6004652-PU.PDF ).
Tax returns are confidential information but I know I could get the KY Dept. of Revenue to let us know if the company
would qualify as a Certified Small Business Entity based on their average gross receipts for the last three years based on
less $485,000 or less than $7 million (http://www.chfs.ky.gov/NR/rdonlyres/6DOFA82A-EBA8-47CB-9C3D6A1C872F1921/0/RPS526 Small BusinessEntity Certification1212014.pdf) should we make them apply for a license.
Maybe good information to have should we pursue legal action against the company to remove the wastes disposed of
here in KY and dispose of it a properly permitted landfill in another state.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky .gov Id ph/radioactive. htm
,..Ayour fees on line at https:ljprd.chfs.ky.gov/rad epay/
~notified of proposed regulation changes https:ljsecure.kentucky.gov/Regwatch/
GP453
l(t/Jflj~
P.AiilATiONAh.J.ilMLTH
To: Pendergrass, Curt (CHFS DPH); McKinley, Matthew W (CHS-PH)
Subject: FW: RE: Advanced TENORM Services

.. .
----s~nt:"'fhursday,-February-041-2016-10:-H-PM
To: Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney (EEC)

Chris and Rodney;
As f recall Cory gave the impression that the web site was something he didn't keep up with, it was created awhile back
and he no longer worked or was actively involved with the listed "Vice President - Dr. Leong Ying." He also said Dr. Ying
was not a member of the corporation.
So much I am trying to sort out regarding what Cofy told us.
'

George
(jeorge P. Partrit[ge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP454
-m:
Subject:

Tracking:
Recipient
Delivery
Read
Keffer, Christopher (CHFS Rad

Hlth)
Read: 2/8/2016 8:19 AM
Sent:
To:
Chris;
I have meetings scheduled as follows on Tuesday and Thursday:
Tuesday 12-4
Thursday 1-5
I am available the balance of the time on Tuesday and Thursday.

Wednesday, George Weems, the Field Inspector that is responsible for Blue Ridge Landfill and I plan to make a site visit
to the landfill and would like very much if you could join us on that date. This is the landfill that received the waste from
~rmont Brine in WV that has elevated levels of radioactivity for TENORM present. I also understand there is a school
F o s s from the entrance to the landfill. This will be my first site visit there.
If at all possible it would be great if you are someone in your group could join us and check the area for radioactivity,
especially arou-nd the solidification pit, etc. - and also be part the meetings with landfill officials. They are asking a lot of
questions about TE NORM and it would be helpful to have you there with your expertise.
Let us know if you can join us on Wednesday. George Weems wants to leave from the Lexington area around 7:30 and I
will be leaving prior to that from Frankfort to meet up with him. If this doesn't work with your schedule, I will seek to
coordinate a day and time with him that works for us all.
This situation with TENORM is my highest priority and any meetings and site visits will take precedence over meetings to
discuss projects.
I look forward to us reviewing our findings and discussing the course of actions that can potentially be taken.
Thanks again for being so generous with your time and all the helpful information you have shared with me.
George

I

_a.Pendergrass, Curt (CHFS DPH); McKinley, Matthew W (CHS-PH)
rject: Advanced TENORM Services
George,
GP455
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
f'~]{: ~Q2-56_4:_H~g
_____ __
GP456
!elm:
Maze, Rodney (EEC)

Re: Green Valley
Sent:
To:
Subject:
I will get with you Monday and we can schedule a date and time. Are we doing a multi media site visit with the Radiation
Branch?
I was looking today at the documents we obtained from Green Valley and the rad sampling was conducted by Advanced
TeNorm Services
Rodney Maze

Rodney;
Thank you! I would like to make a site visit to Pressure Tech and Big Run. George Weems and I plan to
make a visit to Blue Ridge on Wednesday of next week.
Let me know you thoughts on making visits to facilities in your region.
Thanks again for the opportunity to join you and Karen yesterday and all you did.
George

Subject: Fwd: Green Valley
Attached is the Tenorm waste documentation from Green Valley Landfill we obtained yesterday during
the site visit
Rodney Maze


1
GP457
flam:
Sent:
To:
Subject:
Attachments:
Tracking:

RE: Laboratory Certification for Advanced Tenorm Services
Advanced TENORM Sample Summary.pdf; Advanced TENORM Services - Photos 020416.pdf
Recipient
Delivery
Hi Samantha;
Thank you for meeting with me and being very generous with your time this morning to discuss the lab certification for
Advanced TENROM Disposal.
We learned that Advanced TE NORM Disposal also did the rad testing for waste that was sent to Green Valley Landfill in
the Ashland area that is managed by Republic Services.
I have attached an example of one submittal that we obtained yesterday on our site visit to Green Valley. We requested
Green Valley to pull all their manifests that showed out of state waste coming from counties in OH that are known for
_Acking operations and often contain TENORM.
S ' r y Hoskins, the "President of Advanced TENO RM Services" has also been sending out of state waste to Green Valley.
We have additional site visits, meetings, etc. scheduled for next week as our investigation continues.
I look forward to us keeping in touch as we proceed with tracking down all this illegal waste disposal operations that
Corry managed.
If you feel that an investigation is justified by you and your section based on the additional information I am sending
you, please do not hesitate to take whatever action you feel is appropriate.
I will continue to keep in touch with you in the days and weeks ahead as we learn more.
I also attached an electronic copy of the photos I shared with you this morning.
Thanks again for your help!
George
(jearge P. PartridfJe Jr., Pfu;(, P.'E., Q'EP

~Fair Oaks Lane; 2nd Floor (SWB)
.kfort, KY 40601
1
(502) 564-6716 ext. 4651
GP458

___
Sent:_Wednesday,Eebrnacy~03,
2016-4:42 PM ....
Subject: Laboratory Certification for Advanced Tenorm Services
Hi George,
Thank you
Samantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
{502) 564-0111 Fax
GP459
-om:
Sent:
To:
Cc:
Subject:

Weems, George (EEC)
RE: Site Visit to Blue Ridge on Wednesday - February 10th
George;
I look forward to our site visit to Blue Ridge on Wednesday with plans to meet you in Lexington at 7:30 AM.
I contacted Chris Keffer to see if he can join us. I will follow up with you Monday.
I copied Chris's contact information below.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
""an ks for stopping by earlier today.

George
(jeorge P. PartrUfa,e Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP460
To:
Subject:

RE: RequestApproval for Block-SO
Lindsey;
With my site visits last week and TE NORM work in addition to my regular review assignments I am well over 240 hours
of comp time now.
I have plans to join both George Weems and Rodney Maze for additional site visits this week. With the analytical results
coming in on the radioactive waste shipments and all the correspondence and questions I am receiving and researching,
I have a very busy schedule ahead of me in the near future.
Also Tim Oaks is also requesting a site visit for J K Smith.
I request approval to earn a Block 50 this pay period so I can adequately address the issues surrounding the radioactive
waste that is going to our landfills in eastern Kentucky. We have only confirmed one company in detail, but other
companies as well are involved and shipping wastes from Ohio and West Virginia.
I am seeking to protect the well-being of our landfill operators and managers whose health and well-being have already
'"compromised.
Thank you for considering my request.
George
(jeorge P. PartrUfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
.1
GP461
#m:
Sent:
To:
Subject:
Attachments:

FW: Laboratory Certification for Advanced Tenorm Services
Samantha;
When you received my email and have had time to review it, I would like to discuss it with you.
Thank you,
George

To: Kaiser, Samantha (EEC)
_
Subject: RE: Laboratory Certification for Advanced Tenorm Services
Hi Samantha;
~ank you for meeting with me and being very generous with your time this morning to discuss the lab certification for
We learned that Advanced TENO RM Disposal also did the rad testing for waste that was sent to Green Valley Landfill in
fracking operations and often contain TENORM.
Cory Hoskins, the "President of Advanced TENO RM Services" has also been sending out of state waste to Green Valley.
Corry managed.
attached an electronic copy of the photos I shared with you this morning.
GP462
George
(jeorge P. Partric[ge Jr., Pfid; P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Hi George,
I believe you left me a voicemail on Friday Jan 29 concerning a laboratory Advanced Teno rm. I tried to return your call
Thank you
Samantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
(502) 564-0111-Fax
GP463
e!:~:
To:
Subject:
Attachments:

RE: Analytical Results Submitted by Advanced TENORM Services
Advanced TENORM Sample Summary (2).pdf
Tracking:
Recipient
Delivery
Curt;
I, along with Rodney Maze and Karen Hall from our Regional Field Office in Morehead for the Division of Waste
Management visited the Green Valley Landfill in the Ashland area run by Republic Services last week.
We reviewed manifests during our site visit and identified wastes being sent from Ohio with the paper work signed by
Cory Hoskins associated with Advanced TENORM Services. The analytical work submitted with the waste shipments was
also provided by Advanced TENO RM Services. I have attached one of the submittals so you could see what is being
submitted. I question the accuracy of the analyses that I saw. If the analytical results were as low as they the paperwork
presented, I do not understand the need to ship the waste to Kentucky at a higher cost to the company.
~-el it is important to confirm that the waste was actually analyzed by a certified lab. When we met with Cory he
__..icated he had equipment to measure the radioactivity, but he did not use it for analysis.
George Weems an inspector from the Frankfort Office and I plan to visit Blue Ridge Landfill on Wednesday where the
waste from WV (Fairmont Brine) was sent. We plan to meet with management at the landfill and review manifests.
We would like very much if someone from you area, especially Chris Keffer could join us for the site visit so we can
screen for contamination while we are there. Also having Chris present to respond to questions and concerns regarding
radioactive materials would be very helpful.
Advanced TE NORM Services is listed with the Division of Water as a Certified Lab for pH, TSS, and 0 & G. They are on
Interim Status since they are new. The lab is at their company address in the Morehead Head County Public Library is
the size of about two cubicles. There is no sink or water in the office and I do not see how they could run a lab at the
library. If they did they would be using the public restrooms in the library to clean up their equipment, etc. from
analyzing wastewater which would put the public at risk. I have addressed my concerns with the DOW.
I am continuing to investigate our concerns regarding TENORM and seek to do all I can to protect the personnel at the
landfills and the communities they serve.
Please continue to copy me on correspondence.
I am available to participate in any meeting or visits as we need to. This is my highest priority .
nks again for all you and your group are doing!
.George
(jeor9e P. Partricfoe Jr., Pli'JJ, P.'E., Q'EP

1
GP464

Frankfort, KY 40601
(502} 564-6716 ext. 4651
GP465
#m:
Sent:
To:
Subject:

Based upon these results, we need to add some parameters to the list I came up with from the published data.
This is higher than much of the stuff DOE puts in their landfill.
Potassium-40 26.630 :t 19.036 (17.130)
C:NAT:NA
EPA 901.1 pCi/g 06/15/15 16:51 13966-00-2
Radium-226 1453.500 :t 200.780 (44.630)
C:NAT:NA
EPA 901.1 pCi/g 06/15/15 16:51 13982-63-3
Radium-228 303.750 :1: 40.774 (7.817)
C:NAT:NA
EPA901.1 pCi/906/15/1516:5115262-20-1
Scandium-461.268:1:1.784 (1.774)
C:NAT:NA
EPA 901.1pCi/g06/15/1516:5113967-63-0
Silver~ 11 OM 2.381 :t 1.567 (1.549)
C:NAT:NA
EPA 901.1pCi/g06/15/15 16:5114391-76-5
Thorium-232 162.200 :t 392.170 (478.000)
C:NAT:NA
901.1 pCi/g 06/15/15 16:51 7440-29-1
ium-238 94.336 :t 17.406 (17.780)
AT:NA
901.1 pCi/g 06/15/15 16:51
REPORT

To: Hendricks, Todd (EEC)
Subject: RE: TENORM Environmental Monitoring
Todd;
identify constituents that should be monitored for in TENO RM wastes.
, ks again,
George
GP466
. From: Hendricks, Todd (EEC)

FYI

--To:~Aldr-idge,-Louanna-(EEC)~.~-.~"-~~~~--- . -----
-------c---------"'------ --- - - - - - - - -
---~--
--
-~-
----~
--- ------'---- ----'.---'-'-
~-----__:._--~-
--------

Louanna,
Radium-226
Radium-228
Polonium-210
Lead-210
Radon - forms from the decay of radium; preferentially follows other gases, can end up in landfill gas, prefers ethane.
'
Groundwater: A landfill that has accepted TENO RM should already have a functioning groundwater monitoring system
be an issue.
pathways.
..
Regards,
Todd
GP467

. . .m:
To:
Sent:
Subject:

Read: Advanced TENORM Services
Your message
To: Keffer, Christopher (CHFS Rad HlthY
Sent: Friday, February05, 2016 7:01:16 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Monday, February 08, 2016 8:19:21 AM (UTC-05:00) Eastern Time (US & Canada) .
GP468
To:
Subject:

Would meeting here tomorrow at 9 am be a good for you?
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only tor the use of the individual or entity to which it is addressed and may

_&Keffer, Christopher (CHFS Rad Hlth)
_......1ject: RE: Advanced TENORM Services

Chris;
Tuesday 12-4
Thursday 1-5

Fairmont Brine in WV that has elevated levels of radioactivity for TE NORM present. I also understand there is a school
across from the entrance to the landfill. This will be my first site visit there.
especially around the solidification pit, etc. - and also be part the meetings with landfill officials. They are asking a lot of
questions about TENO RM and it would be helpful to have you there with your expertise.
cidinate a day and time with him that works for us all.
. h i s situation with TENORM is my highest priority and any meetings and site visits will take precedence over meetings to
discuss projects.
GP469
George

. - ...Cc~J?.ende[grnss,_Cud:_(C_HE.S. QPtl);J-,'l<::KLnJ~y, M9.l:tb~~W
(Clj$-P.ttJ
George,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
review, use, disclosure, distribu.tion or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
a.
GP470
~m
Sent:
Subject:
Attachments:

Fitzpatrick, Chris (EEC)
Tracking:
Recipient
Delivery
To:
Chris;
Here is the correspondence I received from Curt Pendergrass last Friday. We have been keeping in touch on a regular
basis for the last several years. Jon Maybriar who is our Assistant Director for the DWM would not let Curt's employees
accompany me to landfills last week when we were investing this. He told me he didn't want Curt's group involved. I
know Curt was pushing for a meeting and for working with us. I hope he will get his meeting.
My management as well as the Hazardous Waste Branch only response to me is to send out courtesy letters to the
facilities so they will be aware of these shipments. When the company sending the waste is misrepresenting themselves
and not accurately labeling the waste, how will they know what they are receiving at the landfills?
~~I want to know is if something is being done!
S i s situation has jeopardized the health of the landfill operators and our inspectors who regular visit this facility.
The landfill where this went to has a school across from the entrance from what I understand. The dust and particulates
from the incoming trucks is a concern.
I feel people's lives will be shortened from what has taken place.
This is just one company. Other companies are also sending their waste to Kentucky!
I wish the Governor's office would place a moratorium on any out of state Fracking Wastes or Oil & Gas Waste until
we can get some protective measures in place.
This is processed waste where the radioactive materials have been concentrated!
(This also has the website for the company included.)
George

Friday, February OS, 2016 2:50 PM
..AFrame, Jason R
wa!'Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); McKinley, Matthew W (CHS-PH); Anderson, Danny J
Sent:
GP471
and gas production fluid processing tanks at Fairmont Brine Products (http://www.fairmontbrineprocessing.com/ ). And. . .
~
Ani=!IYliC:B_L<ln9Jy~is <rnd thaJ;ltwasjf\/9.ste ManaE~flJ~D! thCI! t()_(dfBP thcit the D1<:t!_e_ri~L ne~clecj t() be !c:iken ou_t_~~~!.!c:>a
much lower bid from Advanced TE NORM Services of West Liberty, KY (http://advtenorm.com/) makes the company
how best to address this issue since the wastes is now buried at several municipal solid waste landfills here in KY. Again,
we just can't thank you enough for all your assistance in this matter.
Curt
AN.ALYTICAL SESULT$ -RADIOCH.EMISTRY

Project
fairrncmt Brine ~ Studge Pit Cl
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'
[,

Mailstop HSlC-A
Frankfort, KY 40621
'
1.:
Tel: 502-564-3700 ext. 4183

2
GP472
Fax:502-564-1492
.......ilebsite: http://www.chfs.ky.gov/dph/radioactive.htm
~.n.
.~

'

Office: (304)356-4303
(304) 558-0524
Sffiail: Jason.R.Frame@WV.gov
....9c:

To: Frame, Jason R
- k s Jason. That is exactly what I was hoping to hear. A WV regulation referencing a drive through radiation portal
3
GP473

Curt PendergrassPhD
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
E-mail: curt.pendergrass@kv.gov
:~


WV DEP is not involved ip any type of radiological permitting. I believe you are referring to the drill cuttings disposal regs

Office: (304)356-4303
Fax: (304) 558-0524
GP474
To: Frame, Jason R _


Hello Jason,
Jsume th~ driving force behin_d FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
-~~ber was the radioanalytical analysis of this wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on
sludge. The West virginia oepartment of Environme

processed FBP's Notification of Regulated Waste Actl
Environmental Prote-ction Agency (US EPA) tdentifica
.
GP475
Subdivision 16.12.c. and Subsection 16.13. Usingpwposeful dilution to render TENORNI
waste exempt shall not be allowed witlwutprior agency a proval.
Just to let you know, while KY lacks specific regs addressing TENO RM, our Central Midwest Interstate Low-Level Waste '
Compact of which KY is a member along with IL, specifically prohibits the disposal ofout-of-cornpact wastes here in KY.
(RCRA}" will be~question fo~ my colleagues in the Energy and EnvironmentCabineuo answel".But-if_youactuaL"--
Thanks,
Curt

s~~l~e,tpe exclusive regul~t?ry resp?nsib~lit~. ofthe states, ~k~Ptth~l;4p R~f~pi1
Jfll:~ itfkilit!l&\titi~~li!Bit.I~~~~@:
1

tehthousand dollars ($10,000) nor more than one hundred thousand dollars
offense.
'

r~dioa~ti;rity(Jf ro~ks o: soils: or bac~~round radi~tio?! bu,t inste.ad K:~~~rs:?t9:
~}J~~~~tl~~~~it~~fl!~}j~~i~i~qfu\gliifq~1i~~hR~~~~;~&"~cP:f!tr~1m~1~:~r~"~tj~~~

Mailstop H51C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
6
GP476
Fax: 502-564-1492
~bsite: http://www.chfs.ky.govId ph/rad ioactive. htm
r y your fees on line at https:t/prd.chfs.ky.gov/rad epay/

Brine
attatchment

Office: (304)356-4303
Fax: {304) 558-0524
7.
GP477

To: Frame, Jason R
Jason;
I wil I be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding'
TENORM disposal.

GP478
~orge
(jeorge P. Partridge Jr., Pfi'D, P.'E., Q'EP
Frankfort, KY 40601
(502) 564-6716 ext. 4651

Office: (304)356-4303
Fax: (304) 558-0524
GP479
I -- -

To: Frame, Jason R
Hello Mr. Frame,
'

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
10
GP480
'

: Webb, April (EEC); George.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Mr. Pendergrass,

Office of Environmental Health Services/Radiation, Taxies and Indoor Air Division
Office: {304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,

includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this e~
11
GP481
is required.
Regards,
Mailstop HS1C-A
frankfort,_KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
'

Dr. Pendergrass,
I was contacted this morning by Mr. Jason R. Frame; a member of the WestVirginia radiation program. He was
inquiring about a West Virginia company's intent to dispose of TNORM from a "tracking" operation here iri Kentucky by
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIOENTIALITY: This e~mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
12
GP482
-om:
To:
Sent:
Subject:
Microsoft Outlook
Delivered: FW: TNORM disposal in KY

Fitzpatrick, Chris (EEC) (Chris.Fitzpatrick@ky.gov)
GP483
-m:
Partridge. George (EEC)
Sent:
To:
Subject:
Attachments:

FW: RE: Advanced TENORM Services
Advanced TENORM Services - Photos - 020416.pdf; Advanced TENORM Services.pdf;
BES LLC.pdf; BES Technical Solutions.pdf; Bluegrass Environmental Services.pdf;
Organizers of LLCs.pdf
Chris;
Thank you,
George

Cc: Maze, Rodney (EEC); Briggs, Lindsey (EEC)

Chris;
_9
W:ell
we discussed Thursday evening, I searched the Internet to locate both the web site for Advanced TENORM Services as
as any business activities of Cory Hoskins or family members. It appears they have been involved in numerous LLC
formation activities in recent years Please find the documents I located related to that search. I have also included the
photos I took from the site visit which shows the Kentucky Office of Advanced TENO RM Services.
I look forward to us keeping in touch and continuing our investigation.
Thank you,
George
(ieorge P. Partrit:fae Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP484
-m
Sent:
To:
Subject:

FW: RE: TENORM in Landfills in Kentucky
Chris;
No one on this email acknowledged that they received it or followed up with me.
George

To: Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Hatton, Tony (EEC)
that includes:

is proactively addressing the situation. WV has impending regulations to address TENO RM disposal. Out of state
Ohio, WV, PA and other states moving forward with regulations, waste is now being diverted to Kentucky.
I have 9een corresponding with Dr. Curt Pendergrass, Supervisor of the Radioactive Materials Section for the Kentucky
protect the environment. My concern is that TENORM waste may be received by landfills that are not aware of its
radioactive nature.
George
WtBe P. Partridjje Jr., Pfi'D, P.'E., Q'EP
~artment for Environmental Protection

1
GP485
Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP486
tf/!om:
Subject:

Tracking:
Recipient
Delivery
Sent:
To:
Chris;
A follow up email specifically to Lindsey, my supervisor when I got no response from my previous email message that
was addressed to Lindsey, Tony, and Danny.
George

ldsey;
was referred to Jason Frame by Kevin Koska, Vice President of Compliance/Regulatory Affairs for Shale Mountain
Resources.
and Pressure Tech are taking all their TENO RM waste (that is too highly concentrated to enter or tha.t hii!S been rejected
in excess of 600 pCi/g were disposed of in Kentucky. The waste was received in Kentucky by Advanced TE NORM Services
NORM (TENORM) and then dis~oses of it at Blue Ridge Landfill in Irvine, KY. There are plans to continue shipment of this
waste to Kentucky.
reached me.
Jason told me the waste is often just labeled as "tank bottoms" or "sludge" .
, , it is very important that someone investigate the company" Advanced TENORM Services" located here in Kentucky
as well as the landfills that have been brought to our attention that are accepting TENORM.
GP487
Thank you,
George
From: Frame1 :'Jasen-R-[mailte:.Jason.R.-Frame@wv.gov]


Office: (304)356-4303
Fax: (304) 558-0524
'

To: Frame, Jason R

Hello Mr. Frame,
TENO RM Services of Liberty, KY (http:Uadvtenorm.com/ ). We will follow up with the company's president, Cory
2
GP488
..

East Main Street
ilstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
___,,...,.,
. .Y

Mr. Pendergrass,
11
1rating as Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please
- - - _ise on this issue. Thanks

Office: (304)356-4303
Fax: (304) 558-0524
.,m:
To: Frame, Jason R

3
GP489
Hello Mr. Frame,
&..
While KY does not currently have any regulations dealing with the control and disposal of NORM[TENORM waste
generated in the oil and gas industry from hydraulic fracturing, we do have statutes on the books establishing the Central. . .
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM[TENORM in landfills here in KY is their
regulatory purview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM[TENORM
. contaminatedwaste so.Advanced.TENQRMServices.mlghtwantoto cnee...kwithlhe...authoritie~JnlliO~f:! ~tat~~ to ~e~ \IYl"l_C!L.
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
intended recipient orthe person responsible for delivering the e-mail to the
herein.
'


Dr. Pendergrass,
999 ). From Mr. Frames understanding, Advanced TENO RM Services L.L.C. (located in West Liberty, KY) will be solidifying
GP490
East Main Street, HS1 C-A
nkfort, KY 40601
. Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
review, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this.communjca!ion in error, please contact the
sender by reply e-mail and destroy an copies of the original message.
GP491
--m:
To:
Sent:
Subject:
Microsoft Outlook
Delivered: FW: TENORM disposal in KY

Fitzpatrick, Chris (EEC) (Chris.Fitzpatrick@ky.gov)
GP492
To:
Subject:

Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W
(CHS-PH)
FW: NORM/TENORM Industry Day Participants
GP493
t.f.s. POT, Offlc~(ifHazardous MaterialsEriforcement

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. NOR Ml~~usi.fYp~Y~~a~~n\~euer.com. wear~ 'byildiDg gr.1 i~ts pf.
. _inte.restep~ttt:p.d.~~,7~.~e:~J~.ntt,Ss~(f~~illZp~o~sl~L),_g~h .ibi~Q r.s~~a.rJg. ._p9~~-... .

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Dade Moeller & Associates, Inc., 1835 Terminal Drive,

Suite 200, Richland, WA 99354
SafeUnsubscribe curt.pendergrass@ky.gov
Forward this email to a colleague I Update Profile I About our service
provider
Sent by bd@dademoeller.com in collaboration with
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GP494
Sent:
Subject:

Read: RE: Analytical Results Submitted by Advanced TENORM Services
Your message
Subject: RE: Analytical Results Submitted by Advanced TENORM Services
Sent: Monday, February 08, 2016 8:06:17 AM (UTC-05:00) Eastern Time (US & Canada)
was read on Monday, February 08, 2016 8:43:27 AM (UTC-05:00) Eastern Time (US & Canada).
GP495
---m
Sent:
To:
Subject:

RE: RE: Request Approval for Block-SO
Lindsey;
Thank you,
George

Cc: Anderson, Danny J (EEC)
Subject: RE: RE: Request Approval for Block-50
This is the last one. Start taking Fridays off if necessary to get your hours down.
Lindsey Briggs, PE
Jvironmental Engineer Supervisor
. . .02 564 6716

Subject: RE: Request Approval for Block-50
Lindsey;
With my site visits last week and TENORM work in addition to my regular review assignments I am well over 240 hours
of comp time now.
I have plans to join both George Weems and Rodney Maze for additional site visits this week. With the analytical results
coming in on the radioactive waste shipments and all the correspondence and questions I am receiving and researching,
I have a very busy schedule ahead of me in the near future.
Also Tim Oaks is also requesting a site visit for J K Smith.
I request approval to earn a Block 50 this pay period so I can adequately address the issues surrounding the radioactive
waste that is going to our landfills in eastern Kentucky. We have only confirmed one company in detail, but other
. .panies as well are involved and shipping wastes from Ohio and West Virginia.
I am seeking to protect the well-being of our landfill operators and managers whose health and well-being have already
been compromised.
1
GP496
Thank you for considering my request.

George
(jeorge .P. Partridge Jr.

_Er~o1<fort,JSY _~tQ~O L _ ~- __
(502) 564-6716 ext. 4651
'
GP497
-m:

RE: NORM/TENORM Industry Day Participants
Sent:
To:
Subject:
Curt;
Thank you,
George
.From: Pendergrass, Curt (CHFS DPH)

To: Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH)
Subject: FW: NORM/TENORM Industry Day Participants
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Dade Moeller & Associates, Inc., 1835 Terminal Drive,

Suite 200, Richland, WA 99354
SafeUnsubscribe TM curt.penderqrass@ky.gov
Forward this email to a colleague I Update Profile
provider
I About our service
Sent by bd@dademoeller.com in collaboration with
Try it free today
GP499
#um:
Sent:
To:
Subject:

Chris:
Tomorrow at 9 AM will be great! Please let me know the conference room or where I need to go. Also I assume I will be
meeting you at the street office below. This will be my first visit to you offices.
Thank you,
George
Sent:

ristopher J. Keffer
diation Health Specialist Ill
275 East Main Street, HS1C-A
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
Sent:

Chris;
Tuesday 12-4
Thursday 1-5
available the balance of the time on Tuesday and Thursday.

1
GP500
Fairmont Brine in WV that has elevated levels of radioactivity for TENO RM present. I also understand there is a school
._
. - coordinate.a day and time with him that works forJJs.alL
discuss projects.
George
Cc: Pendergrass, Curt (CHFS DPH); McKinley, Matthew W (CHS-PH)
Sent:
'
George,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP501
ti!~=
To:
Cc:
Subject:

Todd;
Thank you. As I continue to received more analytical results regarding the shipments of radioactive waste to Kentucky, I
will share them with you.
George
Based upon these results, we need to add some parameters to the list I came up with from the published data.
This is higher than much of the stuff DOE puts in their landfill.
--assium-4026.630:t19.036 (17.130)
S'~AT:NA
EPA901.1 pCi/906/15/1516:5113966-00-2
Radium-226 1453.500 :t 200.780 (44.630)
C:NAT:NA
EPA 901.1 pCi/g 06/15/15 16:51 13982-63-3
Radium-228 303.750 :t 40.774 (7.817)
C:NAT:NA
EPA 901.1pCi/g06/15/15 16:51 15262-20-1
Scandium-461.268:t1.784 (1.774)
C:NAT:NA
EPA 901.1 pCi/g 06/15/15 16:51 13967-63-0
Silver-110M 2.381 :t 1.567 (1.549)
C:NAT:NA
EPA 901.1pCi/g06/15/1516:5114391-76-5
Thorium-232 162.200 :t 392.170 (478.000)
C:NAT:NA
EPA 901.1 pCi/g 06/15/15 16:51 7440-29-1
Uranium-23894.336:t17.406 (17.780)
C:NAT:NA
EPA 901.1pCi/g06/15/1516:51
REPORT

. .d;
identify constituents that should be monitored for in TENORM wastes.
GP502

__ .
Ihanksagain,_~
George

FYI

Louanna,
Radium-226
Radium-228
Polonium-210
Lead-210
Radon - forms from the decay of radium; preferentially follows other gases, can end up in landfill gas, prefers ethane
'
Groundwater: A landfill that has accepted TE NORM should already have a functioning groundwater monitoring system
be an issue.
2
GP503
~Landfill gas could contain Radon; some will be released directly from the landfill into the air through cover or the
pathways.
Regards,
Todd

Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4653
GP504
To:
Subject:

Yes the street address below is correct, once you get here the guard at the front should page our office to let us know
that you are waiting. If there is anyone else in your office who you think should sit in on the meeting feel free to bring
them along.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564'."1492
m: Partridge, George (EEC)
nt: Monday, February 08, 2016 8:53 AM


Chris:
Thank you,
George


East Main S.treet, HS1 C-A
kfort, KY 40601
502-564-3700 x4179
-Cell:
' 502 330-7662
FAX: 502-564-1492
1
GP505
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which ii is addressed and may
review, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the , . _
sender by reply e-mail and.destroy all copies of the original message.
''"""'-'"~ ~'~"" H~> "~'M""'"-r-,,---~~'"'"'""'~'""~-~~~ e~~~-K>~-~<'-~'.Wu<H~

Tuesday 12-4
Thursday 1-5

especially around the solidification pit, etc. - and also be pa. rt the meetings with landfill officials. They are asking a lot o f '
discuss projects.
George

Cc: Pendergrass; Curt (CHFS DPH); McKinley, Matthew W (CHS-PH)
George,
Tuesday, Wednesday or Thursday next week in order to discuss our findings and possible actions that will be taken .
2
GP506

Frankfort, KY 40601
Ph: 502-564-3700 x4179
502 330-7662
9'1"AX: 502-564-1492
.-Au:
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the in.dividual or entity to which it is addressed and may
GP507
-m:
Sent:
To:
Subject:

Chris:
Look forward to seeing you at 9 am in the morning!
George

them along.
iation Health Specialist Ill
East Main Street, HS1C-A
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed ;md may

Chris:
Thank you,
George
~=l<~(f~;; ch~i;t~~h;;(cHFs-R~d--Hlth)--- .......................

' Sent: Monday, February 08, 2016 8:29 AM
I
GP508

Frankfort, KY 40601
. . . Ph: 502-56A.-.3100.x4179 _
Cell: 502 330-7662
FAX: 502-564-1492
review, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this comn:iunication in error, please contact the

Chris;
Tuesday 12-4
Thursday 1-5

Fairmont Brine in WV that has elevated levels of radioactivity for TENO RM present. 1 also understand there is a school
questions about TENO RM and it would be herpful to have you there with your expertise.
discuss projects.
Thanks again for being so generous with your time and all the helpful information you have shared with me .
George
GP509

: Partridge, George (EEC)
Pendergrass, Curt (CHFS DPH); McKinley, Matthew W (CHS-PH)
George,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP510
Partridf!e Georiie (EEC)
m:
Sent:
To:
Subject:
. .
l
I

RE: Meeting with Rad Mat. Section - TENORM
Lindsey;
Chris confirmed the meeting for tomorrow at 9 AM.
As noted in his email message below, the meeting is open to anyone else that you feel should attend as well. Let me
know if anyone else will be interested in joining me.
George

t you are waiting. If there is anyone else in your office who you think should sit in on the meeting feel free to bring
m along .
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the indivi.dual or entity to which it is addressed and may
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that qny

Chris:
meeting you at the street office below. This will be my first visit to you offices .
. .nkyou,
George
GP511

c_

275EasfMain Street;-FISlC-A
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

Chris;
'
Tuesday 12-4
Thursday 1-5
This situation with TE NORM is my highest priority and any meetings and site visits will take precedence over meetings to
discuss projects.
I look forward to us reviewing our ftndings and discussing the course of actions that can potentially be taken.
GP512
George
....,m:

~~t: Friday, February 05, 2016 9:45 AM
George,
275 East Main Street, HS1C-A
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable law. If the reader ol this message is not the intended recipient, you are notified that any
GP513
-m:
Sent:
To:
Subject:

Let George Weems know and possibly Todd and Jon Maybriar.
Lindsey

Subject: RE: Meeting with Rad Mat. Section -TENORM
Lindsey;
,_~~---------------------
---- --- --

them along.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
. From: Partridge, George (EEC)

t: Monday, February 08, 2016 8:53 AM
I . .
GP514
Chris:
Tomorrow at 9 AM will be great! Please let me know the conference room or where I need to go. Also I assume I will b~.
~
Thank you,
George
From:-Keffer; Ghristopner (GHFBRad Hlth)
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
'
---------------------------------------------------------------------------- -From: Partridge, George (EEC)

Chris;
Tuesday 12-4
Thursday 1-5

GP515
~rdinate a day and time with him that works for us all.
9 1 i s situation with
discuss projects.
TENOR~
is my highest priority and any meetings and site visits will take precedence over meetings to
George

George,
' I wanted to let you know that I have received your emails and to see if you would be available for a meeting
East Main Street, HS1 C-A
nkfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
#.a
contain confidential information exempt from disclosure under applicable law. It the reader of this message is not the intended recipient, you are notified that any
sender by reply e-mail and destroy all copies ot the original message.
1
I
GP516
-m:
Sent:
To:
Cc:
Subject:

Weems, George (EEC); Hendricks, Todd (EEC)
Maybriar, Jon (EEC)
FW: Meeting with Rad Mat. Section - TENORM
George and Todd;

I am scheduled to meet with Chis Keffer with the Radioactive Materials Section at 9 AM at their offices on Tuesday,
February 9th. Chris and I, along with Karen Hall and Rodney Maze conducted a site visit to Advanced TENORM Services
last week in West Liberty.
Lindsey ask me to let you all know if anyone wanted to join me for the meeting.
Thank you,
George
,jed:

Let George Weems .know and possibly Todd and Jon Maybriar.
Lindsey
Subject: RE: Meeting with Rad Mat. Section - TENORM
Lindsey;
George
~ect: RE: Advanced TENORM Services
them along.
1
GP517
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain eonfioon!ial-information exempt from disclosure-under.applicable. law. _Jf .the reader.of lhis message isnoUhe. intended recipient, OUare_notilie.dJbata11y

Chris:
Thank you,
George

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is i.ntended only for the use of the individual or entity to which it is addressed and may
/
GP518
-m:
Sent:
To:
Subject:

If the weather allows, I would like to go.

To: Weems, George (EEC); Hendricks, Todd (EEC)
Subject: FW: Meeting with Rad Mat. Section - TENORM

George and Todd;
t/!:._nk you,
George


Lindsey


Lindsey;
!rge
GP519

them along.
- -~~ Qhri!Ste>Rl:!~L.~ .ISc~ff~r .... ~

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

Chris:
'
Thank you,
George

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and m a y .
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that an
GP520
-m:
Sent:
To:
Subject:

Todd;
Be delighted to have you join me.
Thank you,
George

If the weather allows, I would like to go.
t: Monday, February 08, 2016 9;44 AM

Weems, George (EEC); Hendricks, Todd (EEC)
Subject: FW: Meeting with Rad Mat. Section -TENORM

George and Todd;
Thank you,
George

-sey

1
GP521

Lindsey;
George

them along.
275 East Main Street, HS1 CA
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under 1:1pplicable law. If the reader of this message is not the intended recipient, you are notified that any
'

Chris:
Thank you,
George

2
GP522
Frankfort, KY 40601
Ph: 502564-3700 x4179
Cell: 502 330-7662
FAX: 502564-1492
'
GP523
elm:
Sent:
To:
Subject:

Thanks.
This is a mess. One wonders whether people are just ignoring it because it is going to make somebody look bad.


Todd;
Be delighted to have you join me.
Thank you,
George
9_,__,,,,,,,,_,,_,,_,,,,,~,,,,,,,,~,,_-,,,,,,,,,,_,,,,,,,,,,,,_,,,,,, ' ' '"' ' "' ' "'

rom: Hendricks, Todd (EEC)


If the weather ailows, I would like to go.


George and Todd;
February 9th. Chris and I, along with Karen Hall and Rodney Maze conducted a site visit to Advanced TENO RM Services
Thank you,

1
GP524
To:
..

Lindsey

T~QiJ3rjgg_s1 LiD<:!?_~y_{fECl _ __
-~ _ ______
___ _
Lindsey;
George

To:

them along.
-W
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

To:

Chris:
Thank you,
2
GP525
George
-;;,:-K~ffer, Christopher (CHFS Rad Hlth)

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP526
-m:
Sent:
To:
Cc:
Subject:
Attachments:

Litchfield, Arline (EEC)
Arline;
This email was received from Curt Pendergrass, includes the analytical results for the waste disposed of at Blue Ridge as
well as the letter from the company that processed the waste that was sent to WV.gov.
Thank you,
George

To: Frame, Jason R
-ject: RE: TNORM disposal in KY
~an ks Jason for pointing out my oversight on the attached radiochemical analysis of the sludge obtained from the oil
much lower bid from Advanced TENO RM Services of West Liberty, KY (http://advtenorm.com/) makes the company
Curt
GP527
ANALYTICAL RESULTS RADIOCHEMISTRY
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Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of unwanted sources http://www.crcpd.org/StateSeNices/SCATR.aspx
~-

Sent:
2
GP528

~ce of Environmental Health Services/Radiation, Toxics and Indoor Air Division
~ Capitol Street, Room 313

Office: (304)356-4303
Fax: (304) 558-0524
m:
Pendergrass, Curt (CHFS DPH) [mailto:Curt.Penderqrass@ky.gov]

Frame, Jason R
Mailstop HS1C-A
Frankfort, KY 40621
..._~502-564-3700 ext. 4183
~502-564-1492
3
GP529


-To:-Pendergrassi Gu rt EGHFS DPH)

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Jason,
them for actual data on these loads as to the activity concentration of Ra-226 + Ra-228 plus daughter products? I w o u l presume the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
GP530
9'1udge. The West Virginia Department of Environme

proce;ssed FBP's Notification of Regulated Waste Acti
Environmental Protection Agency (US E;PA) ldentiflca
,
Thanks,
Curt

(3) Naturally-occurring radioactive material (NORM) as defin~d.~~ ~S.211.86~(8)
shall be the exclusive re ulatory responsibility of the states, ~~o~t)tftli~t:fi&?~f~.Q~
,.. I~
~~,,~~~:,,~~lrtl11ille!~
~,~

5
GP531
211.859 or KRS 211.863 arid 211.865 shall be assessed a civil penalty not less than
offense.

H~H"http:Hwww.lrc.ky.gov/statutes/statute.aspx?id~850l

radioactivity (Jf rocks Hor soils, or backgrollnd radiation, \)ut inst~ad ~~f~~~~t~ HHHH H HHHHH.

275 East Main. Street
Mailstop HS1C~A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
E-mail: curtpendergrass@ky;gov
Website: http://www.thfs.ky.gov/dph/radioactive.htm
Pay your fees on line at https://prd.chkky.gov/rad epay/

Level of radioactivity. Exposure rates were be.tween 500 uR/hr and 2 mR/hr
Name of company in Fairmont along with County that contracted with Advanced TENORM Servites. Fairmont
Brine
attatchment
6
GP532

~ice of Environmental Health Services/Radiation, Toxics and Indoor Air Division

Office: (304)356-4303
Fax: (304) 558-0524
,

To: Frame, Jason R

Jason;
TENORM disposal.

7
GP533
George
fgeorge P. Partricfge Jr., Pfi1J, P.T., f;2.TP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: {304)356-4303
Fax: {304) 558-0524
GP534

To: Frame, Jason R
_.lo Mr. Frame,
Fank you for the follow-up e-mail on the purported disposition of WV TENO RM wastes here in KY by Advanced
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
GP535

Mr. Pendergrass,
op~I(3~i~--~s~~~sf\/?nc~d TENO~f\J1 S~r\/i~E!.5_''. !~.continuing to facilitate the dispos~!_o! ~V wast~i~~~ lan~!i~l.~:Please


Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
the disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states ..This obviously
10
GP536
is required.
-ards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
m:

Dr. Pendergrass,
Frankfort, KV 40601
Ph: 502-564-3700 x4179
: 502 330-7662
: 502-564-1492
..
I
11
GP537
-m:
Sent:
To:
Cc:
Subject:

Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); McKinley, Matthew W
(CHS-PH); Anderson, Danny J (EEC); Loyselle, Maridely (EEC); Webb, April (EEC)
Curt,
I'm bringing this up because of discussions WV agencies have had regarding out of state TE NORM. Are the any issues the
language in your compact banning out of state waste conflicting with the Interstate Commerce Act? Thanks

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
and gas production fluid processing tanks at Fairmont Brine Products (http:Uwww.fairmontbrineprocessing.com/ ). And'
~rdous waste landfill specifically license.d for the disposal of radioactive mater.ial. Now that we kno.w yo. ur office put a
~to Fairmont Brine disposing of this material in WV and that the company then contacted Waste Management about
Analytical analysis and that it was Waste Management that told FBP that the material needed to be taken out we~t to a
1
GP538
much lower bid from Advanced TENORM Services of West Liberty, KY (http://advtenorm.com/ ) makes the company
culpable in my book. We will be meeting next week with our colleagues in the Division of Waste Management to decide&...
how best to address this issue since the wastes is now buried at several municipal solid waste landfills here in KY. Again,,..
Curt
Project
P~ Pr.9i~ N9.:
Fairmont Brine "' Sludge Pit Cl

.3Q1~25!i
sam pl&: ..Cl

Riirm-ont
Bli~. S.IUdge Pit
.
.
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Mailstop HS1C-A.
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
GP539

~t: Friday, February 05, 2016 11:10 AM
~: Pendergrass, Curt (CHFS DPH)


Office: (304)356-4303
Fax: (304) 558-0524
To:
Frame, Jason R
alarm of 2X background and 5 pCi/g Ra-226/228 above background, would be great if you can send me ~ link. Also,
- k s again for all your assistance.
3
GP540

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Be.notifiecLofpwposedreguJationchangeshttps://secur:e.kentucky.gov/Regwatch/.
~
"

Ct: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
GP541

- l o Jason,
s.ludge. The West Virginia De,partment of Environme

Environmental Protection Agency (US EPA) ldentiflca
to the actual WV regulation which references this TENO RM limit for disposal in WV. I believe OH chose to use this 5
Ra-226 + Ra-228 plus daughter products as well as their limit for disposal in the regular waste stream.
_M
r/g
Thanks,

5
GP542
(3) Naturally-occurring radioactive material (NORM) as defined inKRS211.86~(8)

.sh~ll bethe exclusive regu~at?ry resp?nsibility of the states, ex:c~FH:h~t~R-JJ~rs-on
iil~lii&lil~'tliil~i~llill'i~~4Y.i

with any administrntivt'Hegulations promulgated pursuant-to KRS~21 l.859 or211.865, or fails to comply with any order of the cabinet issued pursuant to .KRS
($100,000) ..Each day of the violation or noncompliance shall constitute a separate
offense.
practices. Naturally occurring radioactive material does not include.th~natural
ra4i~~ctivityof rocks or soils'. or~a~~9r?und r~di.ation,buti11stea~~~~e~~;ts):
~t~~\i~i~1i'_,
...
d;l
~-i:i{~~IIB919'gisfilfY:1icill~~-~--ljyL~~ilttel!~lJl~iPI~~;ti~~~;

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
.~

6
GP543
Brine
attatchment

Office: {304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.
. - c e s to Kentucky that would be helpful.
GP544

Lknowsome_ottlle aboveitems_OW_ediscussedin Qlff C:Qnyer~ation but. I ~(ls so floored with_!h_~f1E!WS I want to be sure I
George
(jeorge P. PartrUfge Jr., Pfi'D, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

..

Office: (304)356-4303
Fax: (304) 558-0524
8
GP545

To: Frame, Jason R
,Ila

Mr. Frame,
TENO RM Services of Liberty, KY {http:Uadvtenorm.com/ ). We will follow up with the company's president, Cory
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
(;!!'<"
GP546

Mr. Pendergrass,
()f.l_~L~!i!'l_g_~_s_",l\~yanced ~~~()_Rl\t1 ~~l"'i~~es" is continuing to facilitate_t~e~~s!l~sal of WV waste in KY landfills. Please

advise on this i"ssu~. Thanks
-- '--~----~~'--'--~~-'-- ____ ,__ _

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

Hello Mr. Frame,
10
GP547
is required.
-ards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Dr. Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
.......~ 502 330-7662
502-564-1492
.-=
11
GP548
-m:
Sent:
To:
Subject:
Attachments:

RE: Risk Assessment on TENORM by ANL
ANL-NDDH TENORM Landfill Study (ANL EVS-14_13) Final Report.pdf
Jeri;
Please find attached a risk assessment that was conducted by ANL. They eliminated the inhalation pathway since proper
PPE was used for the scenarios in their analysis.
I plan to try to contact the individuals involved with the report and learn more.
Thank you for your help!
George
<georne P. PartrUfee Jr.

.200 Fair Oaks Lane; 2nd Floor (SWB)
Jnkfort, KY 40601
r o 2 ) 564-6716 ext. 4651
1.
GP549
-m:
Sent:
To:
Cc:
Subject:

'Frame, Jason R'
Jason;
Thank you for copying me on correspondence. I will be visiting the site in KY on Wednesday with the inspector from the
DWM, George Weems, where this waste was disposed of from FBP.
George Partridge
KDWM

--t~ringing
..
m
this up because of discussions WV agencies have had regarding out of state TE NORM. Are the any issues the
Jason R. Frame B.S. R.T. {R), Chief Radiological Health Program


Office: (304)356-4303
Fax: (304) 558-0524
-"'' "

1
GP550
To: Frame, Jason R

...
...
and gas production fluid processing tanks at Fairmont Brine Products (http:Uwww.fairmontbrineprocessing.com/ ). And
fiaz<frdouswaste-TanaflHspedflca1ry nc:ens~edforthe disposal of radioactivematerial.-Nowthatwekno-wy<:mroffic:~ pat-a
much lower bid from Advanced TENO RM Services of West Liberty, KY (http:Uadvtenorm.com/) makes the company
Curt
ANALYTICAL RESULTS .. RADIOCHEMISTRY

Project
Fairmont Brine - Slu(ig~ Pitel
,-
.P_a_~-P-_rq__e,ct_-_~_6_;:__3_9_1'00_,_25_~------------------------------------------------------------sample:
Fairl'rt~ntsnne-.Sl1..fcsge PH
. Cf
.
. . . ..
Lab to: :aotsa.2s.s(lp1
CollOOted: 08l08/1509:25 R~iV~: ~515:45
PWS:
Si~10;
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Mab
Results' reported on a "d~gh~ basis
Antlm,t;'ny-124
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2
GP551
t
t
,
1,:
1~
Mailstop HSlC-A
Frankfort, KY 40621
502-564-3700 ext. 4183
~: 502-564-1492
Website: http://www.chfs.ky .govId ph/rad ioactive. htm
_ji
,~


ce ofEnvironmenta. I Health Services/Radiation, Toxics and Indoor Air Division
rleston, West Virginia 25301
Office: {304)356-4303
Fax: (304) 558-0524

~JllW=rame, Jason R
~effer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)
GP552
actual radiochemical data on the loads in questions would be extremely helpful. Does WV actually make companies like . . .
~
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
~'

WV DEP is not involved in any type ofradiological permitting. I believe you are referring to the drill cuttings disposal regs

Office: (304)356-4303
Fax: (304) 558-0524
GP553

To: Frame, Jason R
Hello Jason,
sum. e the driving force behind FBP notifying your office of a regulated waste activity and being assigned a US EPA ID
mber was the radioanalytical analysis of this wastes and not the fact the wastes read 0.5-2.0 mR/hr, I presume on
sludge. The West Virginia Department of Environme

processed FBP's Notification of Regulated Waste Act1
Environmental Protection Agency (US EPA) tdentiflca
{http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?Docld=8395&Format=PDF ). I am hoping that you can share copy or a
GP554
Subdivision 16.12.c. and Subsection 16.13. Using purposeful dilution to render TENOR1l!f
waste exempt shall not be allowed without prior agency approval.
Just to let you know, while KY lacks specific regs addressing TENO RM, our Central Midwest Interstate Low.Level Waste . . .
Compact of which KY is a member along with IL, specifically prohibits the disposal of out-of-compact wastes here in KV.
and production of crude oil, natural gas, and geothermal energy are categorized by EPA as "speeial wastes" and are
(RCRA)ll-willbe questionformyeolleaguesintheEAeFgyaAd !;nvirnnmentGabineU0a1-i.swei:.,..But~t.y.ou~actual
Thanks,
Curt

(3) Naturally-occurring radioactive material (NORM) as defin~din:i<,RS :l~.862(8)
shall be the exclusive regulatory re~onsibility of the states, ~~c}p{tl{~f:.~9:p@rR~
~~Z''' .,~~i~-,.s,,m.;:it!il~~l\!REfy~

offense.
practices. Naturally occurring radioactive material does not include .the natural
radioactivity of rocks or soils, or background radiation, but instead f~'
,
.
'~C""o::.
~~,~~:~.
( :cF;':::".~"'~Vi),~i~9tm2lg~l2lU~J~nb~iip~[';6~~~9:n~,~~,Ac,,,s'' 'f[~!~~~~

Mailstop HSlC-A
Frankfort, KY 4062.1
Tel: 502-564-3700 ext. 4183
6
GP555
Fax:502-564-1492
~bsite: http://www.chfs.ky.gov/dph/radioactive.htm


Brine
attatchment

Office: {304)356-4303
Fax: {304) 558-0524
GP556
To: Frame, Jason R

Jason;
I will be joining our field inspectors at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding,.
TENORM disposal.
Services to kentucky that would be helpful.

GP557
-orge
<;ieorge P. PartrUfae Jr., Pfi'D, P.'E., Q_'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

..
Jason R. Frame B.S. R. T~ (R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
GP558

To: Frame, Jason R
Hello Mr. Frame,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of unwanted ~ources http://www.crcpd.org/StateServices/SCATR.aspx
10
GP559

Webb, April (EEC); Georqe.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Mr. Pendergrass,

350 Capitol Street, Room 313'
Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
isposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously
c des fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
11
GP560
is required.
Regards,
Mailstop HS1C-A
. frankfort, KY_4.0621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Sent: Tuesday, July 21; 2015 1:19 PM
Dr. Pendergrass,
999 ). From Mr. Frames understanding, Advanced TENO RM Services L.L.C. (located in West Liberty, KY) will be solidifying
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330=7662
FAX: 502-564-1492
12
GP561

m:
Sent:
To:
Subject:
Weems, George (EEC)

I'm going to le;;irn it from you. It would be interesting to go though. I told Richard I was doing Blue Ridge and you were
going. I asked if he was interested in going too.


George and Todd;
February gth. Chris and I, along with Karen Hall and Rodney Maze conducted a site visit to Advanced TENORM Services
Lindsey ask me to let you all know if anyone wanted to join me for the meeting .
. . .nkyou,
George


Lindsey


Lindsey;
if anyone else will be interested in joining me.
George
1
GP562
Sent:

them along.
QhrL~tcrnJ1~_r ~~J~_~Jter
Frankfort, KY 40601
Ph: 502-5~4-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

Chris:
'
Thank you,
George
Sent:

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and ma~
contain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that an~
GP563
#.:

Weems, George (EEC)
Sent:
To:
Subject:
George,
Arline Litchfield, a geologist from our Section is also interested in joining us on Wednesday.
Please send me your cell phone number again. I wrote it down but forgot to put it in my phone.
Look forward to meeting you Wednesday in Lexington at 7:30.
George P.
From: Weems, George (EEC)

....
I'm going to learn it from you. It would be interesting to go though. I told Richard I was doing Blue Ridge and you were
I asked if he was interested in going too .
9-ig.
-....... ,. -
,,..
. .. ' "
,,.,.__
..... .....
. ..
...
. ....
..
- ...
'
..

George and Todd;
February 9th. Chris and I, along with Karen Hall and Rodney Maze conducted a site visit to Advanced TE NORM Services
Thank you,
George

.ect: RE: Meeting with Rad Mat. Section
-TENORM
.Let George Weems know and possibly Todd and Jon Maybriar.
Lindsey
1
GP564

Lindsey;
------
-------
------
--
George

them along.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential informatfon exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any

Chris:
Thank you,
George

2
GP565

e'Jould
meeting here tomorrow at 9 am be a good for you?
Frankfort, KY 40601
Ph: 5()2-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP566
-m:

Weems, George (EEC)
Sent:
To:
Subject:
I know Arline. Guess I better shovel the seats clear. Is Arline the geologist for this site?

To: Weems, George (EEC)
George,
George P.
------'
..
..... ,,,_,.....
,_, ,,.,,,,,
~.'
""" ' ' ' ' "' '""'"'"""'''"''"'"'''''
.om: Weems, George (EEC)

Sent: Monday, February 08, 2016
10:53 AM

George and Todd;
Thank you,
!rge
GP567

Lindsey
From:--Paltl'"idge,George (EEC) -
- __


Lindsey;
George

them along.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended ohly for the use of the individual or entity to which it is addressed and may

Chris:
Tomorrow at 9 AM will be great! Please let me know the conference room or where I need to go. Also I assume I will
,
2
GP568
Thank you,
9'fAorge

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
!-
3
GP569
e!~:

Weems, George (EEC)
To:
Subject:
Arline;
She is the geologist assigned to Blue Ridge for our Section in Solid Waste. She expressed an interest in getting familiar
with the site.
George
Please give me you cell phone again so I will have it!
My is: 859-221-8843

.,.
9ow
Arline. Guess I better shovel the seats clear. Is Arline the geologist for this site?
""'"""'"'""-''''"'"'''-"""""'""-""
""""""""""'"""'""""-"""-""""""'""""~""""'"""""""'"""""""'"""""
"'"""' """'"""""""" "
'"" ""

George,
George P.

. g . I asked if he was interested in going too .
"""""'""'""""""""""'"""'"' """"""""""""""'"""""
.
I

1
GP570

George and Todd;
February 9th. Chris and I, along with Karen Hall and Rodney Maze conducted a site visit to Advanced TENO RM Services
Thank you,
George


Lindsey


Lindsey;
Chris confirmed the meeting for-t~t7rrow ilt 9 AM.
George


them along.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
2
GP571
Cell: 502 330-7662

FAX: 502-564-1492
iflCE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
tain confidential information exempt from disclosure under applicable Jaw. If the reader of this message is not the intended recipient, you are notified that any
1ew, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the

Subject:. RE: Advanced TENORM Services
Chris:
Thank you,
George

-)Uld meeting here tomorrow at 9 am be a good for you?
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable Jaw. If the reader of this message is not the intended recipient, you ate notified that any
GP572
~rom:
Sent:
To:
Subject:

RE: RE: TENORM in Landfills in Kentucky
George, I'm looking at the information you sent me, and also checking some statutes and regs on radioactive materials
in Ky.

To: Fitzpatrick, Chris (EEC)
Subject: FW: RE: TENORM in Landfills in Kentucky
Chris;
George

ent: Tuesday, January 19, 2016 8:22 AM
o: Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Hatton, Tony (EEC)
ubject: RE: TENORM in Landfills in Kentucky
'

that includes:
ground as it becomes more costly or prohibited to dispose of TE NORM in other states.
~dioactive nature.
GP573
George
George P. PartridiJe Jr., PfiV, P.T., QTP

Frankfort, KY 40601
_(502) 564:6Zl6 e)tt. AQ_t>l _,~ ________ _
'
GP574

Weems, George (EEC)
.rom:
Sent:
To:
Subject:
502-330-6409.

To:
Weems, George (EEC)

Arline;
with the site.
George
.A1Y is: 859-221-8843
-'"'
..,,,,,,,,~,..
,,,,,,,,,,,,,
'"'''""'''''""'"'"""""'
,.,,,,,,.,,.
To:


To:
Weems, George (EEC)

George,
George P.
I.
1
...~.,,,,,,,,,,,,,,,,,,,..
,, .
om: Weems, George (EEC)
1
GP575

Subject: FW: Meeting with Rad Mat. Section -TENORM
George and Todd;

Thank you,
George

Lindsey

Lindsey;
George

them along.
2
GP576
adiation Health Specialis.t Ill
adioactive Materials Section
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable Jaw. If the reader of this message is not the intended recipient, you are notified that any

Chris:
Thank you,
-eorge
ttF;~;K~ff~~:-ch~istopher (CHFS Rad Hlth)

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
contain confidential information exempt from disclosure under applicable Jaw. If the reader of this message ls not the intended recipient, you are notified that any
GP577
rom:
Sent:
To:
Subject:

Weems, George (EEC)
George,
Thank you!
George


502-330-6409.

ubject: RE: Meeting with Rad Mat. Section - TENORM

Arline;
'
with the site.
George
My is: 859-221-8843



......ubject: RE: Meeting with Rad Mat. Section - TENORM

.eorge,
1
GP578

George P.

To;_Eartridge, George (EEC)
__


George and Todd;
'
Thank you,
George


Lindsey

Subjeq: RE: Meeting with Rad Mat. Section - TENORM

Lindsey;
2
GP579
George
;~.;,;-K~ff~~:ch~i~t~~her (CHFS Rad Hlth)

them along.
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492

ent: Monday, February 08, 2016 8:53 AM
o: Keffer, Christopher (CHFS Rad Hlth)
ubject: RE: Advanced TENORM Services
Chris:
Thank you,
George

Would meeting here tomorrow at 9 am be a good for,.you?
Frankfort, KY 40601
~: 502-564-3700 x4179
~ell: 502 330-7662
FAX: 502-564-1492
GP580
.rom:
Sent:
To:
Subject:

RE: RE: TENORM in Landfills in Kentucky
Chris;
Forgot to send you relevant regulations we are looking at.
I will do that now!
George
From: Fitzpatrick, Chris (EEC)

Subject: RE: RE: TENORM in Landfills in Kentucky
George, I'm looking at the information you sent me, and also checking some statutes and regs on radioactive materials
in Ky.
'
~""''''
rom: Partridge, George (EEC)

Subject: FW: RE: TENORM in Landfills in Kentucky
Chris;
George

To: Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Hatton, Tony (EEC)
that includes:
. a s contacted again this week. I am also expecting a call from Director of the WV Bureau of Radiation Protection who
1
GP581
need for Kentucky to move forward with addressing TENORM waste disposal since our state will become a dumping
ground as it becomes more costly or prohibited to dispose ofTENORM in other states.
I
.
radioactive nature.
George
(jeorge P. Partridge Jr., PliV, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP582

RE: Regulations
.rom:
Sent:
To:
Subject:
Chris;
Here are the regulations that Dr. Curt Pendergrass send me in an email. His contact information is below was well. I will
also send your related regulations that we have in our Solid Waste Branch.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
P.e.. not.ified of.prop. o. sed regulation changes https://secure.kentucky.gov/Regwatch/
ispose of unwanted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
I Ven
IV-.:...,.
~'
,
f')}J'J}A'.ffON .
n.e:\.LTH

arid independent validation as applicable.

-- Prohibitions -- Exemption. http://www.Irc.ky.gov/statutes/statute.aspx?id=8502

1
GP583

offense.
eorge P. Partridge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
'
GP584
Cc:
Subject:

Partridge, George (EEC); Frame, Jason R
McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth)
Hello Jason,
To be honest, I know nothing about the Interstate Commerce Act or who enforces it other than what I just found on
Wikipedia. If you and your colleagues in WV have any information on how this transport of TE NORM from WV to KY by a
private company might be a violation of the ICA, we would love to hear it. We are in the process of paying visits to all the
landfills where this material was disposed of here in KY and based on a conversation with one of the landfill operators,
Republic Services, I can tell you they had no idea what they were accepting.
Regards,
'

ailstop HS1C-A
rankfort, KY 40621
el: 502-564-3700 ext. 4183
Fax: 502-564-1492
Pay your fees on line at https://prd.thfs.ky.gov/rad epay/
V.ontu_CJi~
l~~~-&l~!:l
f'.JU'.JJ,l\7J oN:,tc1.EAt:rn

To: Frame, Jason R
Jason;
George Partridge
"'1WM

1
GP585

I:
Curt,
I'm bringing this up because of discussions WV agencies have had regarding out of state TENO RM. Are the any issues the
Jason-R~
Frame B~S.
R~T.
(R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
I
To: Frame, Jason R
how best to address this issue since the wastes is now buried at several municipal solid waste landfills here in KY. Again, , ,
2
GP586
Curt
ANALYTICAL RESULTS RADIOCHEMISTRY

Project
Pa~ Pt~~ ~9;'.
Fairmon.t Brine ~.Sludge PltCI
31)1$02:55
sampi&: .Fai1montBrtn&-SlucfQe PH
t.abtD: 3015025$0!)1
PWS;
Site ID;
Cl
Colretted.: OO/Oaf1509:25
Redivecl: 06f0$/1515:45
nii&.
'
Anlfrn9rif~f 24
E?A001.1
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EPA!lPU
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ptIlg
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pcifg
06/1511516:51 1
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'l453.02q.D.780 t44.6M)
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J'Gillll
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EPA001.1
162200 J; 392.110
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EPA.90.1.1
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2.sn1 1;~ (1.549J

>;NAT:NA
c;HAJ:MA . .
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.ros
(418J)OO}
(17.780.}

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Sent:

. .o: Pendergrass, Curt (CHFS DPH)
~c: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC)
GP587
Jason R. Frame B.S.
R~ T.
(R), Chief Radiological Health Program

Office: (304)356-4303
Fax: (304) 558-0524
Email:-.Jason.R.Frame.@WV.gov .

To: Frame, Jason R
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
GP588
. a y your fees on line at https:ljprd.chfs.ky.gov/rad epay/
~e notified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
_,-,~
From: Frame, Jason R [11lailto:Jason.R.Frame@wv.gov]


Office: (304)356-4303
ax: (304) 558-0524
mail: Jason.R.Frame@WV.gov
'

To: Frame, Jason R
-elloJason,
5
GP589
..
...

-En-viro"nmental---Protection--Age.ncy-(US_ ERA}~ldentifica.
pCi/g Ra-226 + Ra-228 plus daughter products as w~ll as their limit for disposal in the regular waste stream.
a
See below. How that ties in with the EPA's determination that 11 Wastes generated during the exploration, development,
(RCRA)" Will be question for my colleagues in the Energy and Environment Cabinet to answer. But if you actual
Thanks,
Curt

shall be the exclusive re ulatory res onsibilit of the states, ~~~~fit:tJ1~~-~f{6~n~f'~ij
Tr';"il'~?c\!t~;,.~};'\i,'~tli~
~~t~~~~n:
6
GP590

offense.
practices. Naturally occurring radioactive material does not include the nat\1ral
radioac!i~ityor r?~~s m soils, ()r ~~ckgroundr~diation, butinst~ad.r~f~i'~\!9:
~t~~~i~r~~~i~~t~~rf~~~~Js.:t~~~nQiqgi~a,11y y~tla,rr~.e~ .~i.c,c}nif:9na~1~~~r~ct!:e~

ailstop HS1C-A
ankfort, KY 40621
el: 502-564-3700 ext. 4183
Fax: 502-564~1492

Brine
7
GP591
attatchment

Office: (304)356-4303
Fax: (304) 558-0524- -- - --- Email: Jason.R.Frame@WV.gov
I

To: Frame, Jason R
Jason;
TENORM disposal.

8
GP592
#know some of the above items we discussed in our conversation but I was so floored with the news I want to be sure I
George
(jeor9e P. Partrid[Je Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
From: Frame, Jason R [mailto:Jason.R.Frarrie@iNv.gov]


Office: (304)356-4303
Fax: (304) 558-0524
GP593

To:
Frame, Jason R
Hello Mr. Frame,
Thank you for the, follow-up e-mail on the purported disposition of WV TENO RM wastes here in KY by Advanced
TE NORM Services of Liberty, KV (http:ljadvtenorm.com/ ). We will follow up with the company's president, Cory

275 EastMain Street
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http:f/www.chfs.ky.gov/dph/radioactive.htm
10
GP594

c: Webb, April (EEC); George.Patridge@ky.gov; Loyselle, Maridely (EEC); Keffer, Christopher (CHFS Rad Hlth)
Mr. Pendergrass,
operating as" Advanced TENORM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: {304)356-4303
Fax: (304) 558-0524
To: Frame, Jason R


Hello Mr. Frame,
idwest Interstate Low Level Radioactive Waste Compact of which KY is a member with IL. The compact strictly forbids
e disposal of any and all radioactive materials generated outside of IL and KY anywhere in our states. This obviously
11
GP595
is required.
Regards,
Mailstop HS1C-A
-- -Erankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Dr. Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
12
GP596
To:
Cc:
Subject:

Pendergrass, Curt (CHFS DPH); Partridge, George (EEC)
McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth)
I'm not a lawyer by any stretch of the imagination, but during our TENO RM disposal discussions the problem of out of
state waste has always been at the forefront. Those who know much more about landfill rules than me have always said
that if you take instate waste you have to accept out of state also because of the federal interstate commerce act.

Office: (304)356-4303
Fax: (304) 558-0524

To:
Partridge, George (EEC); Frame, Jason R
Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth)

Hello Jason,
To be honest, I know nothing about the Interstate Commerce Act or who enforces it other than what I just found on
Wikipedia. If you and your colleagues in WV have any information on how this transport of TE NORM from WV to KY by a
private company might be a violation of the ICA, we would love to hear it. We are in the process of paying visits to all the
landfills where this material was disposed of here in KY and based on a conversation with one of the landfill operators,
Republic Services, I can tell you they had no idea what they were accepting.
"egards,
1
GP597

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Be_notifjed_oLp_ropo_sedregulation changes https://secure.kentucky.gov/Regwatch/
Dispose of unwanted
sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
,,,,.,

To: Frame, Jason R

Jason;
George Partridge
KDWM
'

Curt,
I'm bringing this up because of discussions WV agencies have had regarding out of state TENORM. Are the any issues the

Office: {304)356-4303
Fax: {304) 558-0524
GP598

To: Frame, Jason R
'
the elevated U~238 and Th-232 parents, is way over anyone's acceptable criteria for burying waste in anything but a
hazardous waste landfill specifically licensed for the disposal of radioactive material. Now that we know your o. ffice put a
alt to Fairmont Brine disposing of this material in WV and that the company then contacted Waste Management about
el ping them to dispose of this material properly and that it was Waste Management who paid for the attached Pace
. Analytical analysis and that it was Waste Management that told FBP that the material needed to be taken out west to a
Curt
GP599
ANALYTICAL RESULTS RAD10CHEMISTRY

ProJOOt
Pa~ Proit"#t-19.:
f airmont Brine - SIUdg~ P!t Cl

3()15()~55
sam pie:
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Brtne
10:
conect:ed: 06J08/15 09:25
15:45
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.
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(1.~3}
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151151:6:51 11
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00115115 16:51 1:
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(1.77 4)
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(1.549)
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00;15115.16:$1
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2&:63:0 ;t' 11.0,S6 (17.130)

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(478JM)O)
c:Nt\T:NA .
.
&4.33'617..406 (17.780)
CiNAT:NA .
'

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
HWeos1te:HliffP:7Zwww.cnfSXy:gov!dpli[tamoacti\/e~htm
~en~.uCNi
IV.-.IM~-1\o
1~.'(imr1or~&H1U~t.lt1
Sent:

Subject:
4
GP600

.ffice.of Enviro.nmental Health Services/Radiation, Toxics and Indoor Air Division
~~O Capitol Street, Room 313
Office: (304)356-4303
Fax: (304) 558-0524
rom: Pendergrass, Curt {CHFS DPH) [mailto:Curt.Pendergrass@ky.gov]
ent: Friday, February 05, 2016 10:36 AM
o:
Frame, Jason R

Mailstop HSlC-A
Frankfort, KY 40621
a_el: 502-564-3700 ext. 4183
: ~ax: 502-564-1492
I
I
5
GP601

,....~""
""

1"o: Pendergrass, Curt (CHFSDPH)


Office: (304)356-4303
Fax: (304) 558-0524
'

To: Frame, Jason R
Hello Jason,
them for actual.d~ta on these ~oads as to ~h~ activity co~centration of Ra-226 + Ra-~~8 plus da~ghter .products? I would
presume the driving force behind FBP notifying your office of a regulated waste act1v1ty and being assigned a US EPA ID
GP602

Environmental Protection Agency (US EPA) ldentifica
Also, I remember seeing something i.n the lay press about WV issuing new regulations regarding TENORM. However, I
I
Thanks,
Curt

-- Prohibitions -- Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id:::8502
(3) Naturally-occurring radioactive material (NORM) as defi~ecl in ~S 711 :862,(8)

shall be. the exclusive.regulatory r~sponsibility of the states,. y~~~.ptJ~~fl!t~:'p~f.gg
11;;:~'b:'~~;~\fli!l!tl!~~lilli!fl~k~
7
GP603
offense.

http:/Jwww.lre.ky.gov/statutes/statute.aspx?id=8501
ra~ioa~tivityof !()C.ks ()r. s?ils, .or ~ackgroun? ra~i~ti?n, butinstead rif~r:t~.
~;!~~~~itl~M~~~~itl~~tff ~.~~~~19g1a!l~'~11~i~~~(I'H~'~()h~r9,1J~b1~1JraC:tiC3~

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492

Brine
attatchment
8
GP604
.aason R. Frame B.S. R.T. (R), Chief Radiological Health Program

-~ffice of Environmental Health Services/Radiation, Toxics and Indoor Air Division

Office: (304)356-4303
Fax: (304) 558-0524
I
From: Partridge, George (EEC) [inailto:George.Partridge@ky.gov]
To: Frame, Jason R


Jason;
TENORM disposal.

9
GP605

George
<george P. PartridfJe Jr., Pli'D, P.'.E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
I


Office: {304)356-4303
Fax: (304) 558-0524
10
GP606
'

To: Frame, Jason R
-Hello Mr. Frame,
.hank you for the follow-up e-mail on the purported disposition of WV TE NORM wastes here in KY by Advanced
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
11
GP607

Mr. Pendergrass,
~........ OP~r<1ti11_g~a~'~J\~dya11ced 1Il'JQRM Servi~~s" is C()~tinuin~to facilitate the disposal ~f~"\/'!"~s~JE1.~Ylarid!il~s.i!E!.~~e


Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
While KY does not currently have any regulations dealing with the control and disposal of NORM{fENORM waste
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email since disposal of wastes containing hazardous materials including NORM{fENORM in landfills here in KY is their
regulatory purview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM{fENORM
12
GP608
.A
W'
is required .
egards,
Mailstop HSlC-A
Frankfort, KY40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Dr. Pendergrass,

Frankfort, KY 40601
Ph: 502-564-3700 x4179
ell: 502 330-7662
AX: 502-564-1492
13
GP609
Subject:

'skamboj@anl.gov'
RE: TENORM Disposal in Kentucky - Risk Assessment
Dear Sunita;
Thank you for taking time from your busy schedule to discuss our situation in Kentucky (described below) regarding
disposal of TENO RM waste at contained landfills which primarily receive municipal solid waste (all non-hazardous
waste). I have also been reviewing the status of regulation in other states and regulatory development initiatives
surrounding the tracking industry, etc. that generates these wastes. Also there are firms that are now processing these.
wastes resulting in elevated levels of radioactivity in the wastes which are much higher than what is typically thought of
as TENORM.
The report your team produced titled "Radiological Dose and Risk Assessment of Landfill Disposal of Technologically
Enhanced Naturally Occurring Radioactive Materials (TENORM) in North Dakota -Environmental Science Division November 1014" has been an excellent resource and guidance document as we seek to better understand the risks
associated with TENO RM disposal. I was delighted to have the opportunity to learn more about the report and
particularly focus on the results for landfill operations and scenarios that did not include the use of PPE. Thanks again so
much reviewing and explaining sections of the report to me.
-The company, Advanced TENORM Services (www.advtenorm.com) has shipped wastes to two landfills in Kentucky that
. e are apparently aware of. The waste was a sludge like material that was "solidified" (mixed with solids to absorb any
free liquids before placement in the landfill). We are particularly concerned about the safety of landfill operations
personnel who may have been exposed to this material. There is also reason to believe it is being used as "alternate
daily cover." There is a public school across the street from entrance to the landfill.
The particular case we are investigating is summarized below:
Advanced TENO RM Services, LLC shipped 35 truck containers of wastes to a landfill here in Kentucky that had the
following analysis. It was shipped from a firm in West Virginia that processes TENO RM waste known as Fairmont Brine
Processing. The waste had the following analysis:
GP610
ANALYTICAL RESULTS - RADIClCHEMISTRY

Project
P~,P~~f\19.:
f ail'mont Brine~ Sludge Pit Cl

30150255
--------------~~----------------------------------------------------------&amp1&;
.Falmtont
Brine
- Sludge
Lab ID: 301SO~O(}i Col!acted; OSJ08/15 09:25 Receiv64: 06lfl9!15 15:45. Ma~
...
Cl
.
.
.. Pit
Results ~ed on a
"dzy.weigh~ basis
Pai:ame~rs
Method
A.et t Unc {M[)C) carr T~a.c
nlts.
'""An"'"t""'1mo""'.""'ny"'":~"'"12""'4""""""""""""""""""'"""""'.......""""""'""'-EA-iA-.00--t-1------ct'""ooo__b...,.6.....7...
4'""'("'"2'""'.oo"'"~n"'"'"".........,.._'!"'......,. .pc
.....,;"""'u1,1""'. . . , ""'....,061....1"""$t"'"J""'5....1....t,t:""'s1.....". t,
~-1;~
CobaltOO
EPA~1.1
lrkliti.m.,.192
EPA001.1
Pota$$ilm-'40:
EPA001.1
Radlum-'226
EPA001.1
Ra~um~m
EPA001.1
scalldtm-4-ff
SilVeM10M
0,000 :t;.Q.565 (1.6*13)
CiNA T:NA.
0.900 0.634 (1.680}
c:N.&:r.NA
26;63o :ni:l.o~s c1r,13o>
c:NA TtNA
.
1453.50(; t 2QD.780 (44.630)
pCifg
/15l1516:51 11
.j)Cif~
06!1511!?1.6:51 1
J'Gifo
O(i/1$/15 {6~51 1~
pcug
6611511516:51 1:
pcitg
0$/15(151~'.51
EPA.9,11.1
C:HAr:~A
303;750 :1::;.w,774 {UH7}
;:~ T:,"fA ..
1~68.1.784 (tt74)
pCi/g
0011.5t1s1a:$1 1~
EPA001.1
C:N,AT:NA
2.~81 ~.1.strt (1,549)
pCifg
06.l15t1519~51
1.
162.%00.:t:392.110 (478.ooo)
p<;119
~1()11$16:$1
1:
pCllg
06f1511 u1:$1
T~m-232
EPASQ1.1
U~olum-238
EPA91)1J
C~NA T;~A
c:MT:NA . .
. . .
94.33& :t 1t-06 (17 .78,0)
1:
C:NA r.NA
We are presently making site visits to the landfills, reviewing manifests, and should have more details in the weeks
ahead. Once we have an accurate assessment of how the waste was delivered and managed by the landfill, we will be
conducting risk assessment calculations to better understand the risk to the landfill facility and the surrounding
community. Your work and report will help us as we develop our own site specific exposure scenario.
Thanks again for being so generous with your time and helping me with my questions.
Sincerely,
<;]eorge P. PartrUfae Jr., PhD, P.E., QEP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP611
l~rom:
To:
Sent:
Subject:
Microsoft Outlook
skamboj@anl.gov
Relayed: RE: TENORM Disposal in Kentucky - Risk Assessment
destination server:
skamboj@anl.gov (skamboj@anl.gov)
Subject: RE: TENORM Disposal in Kentucky - Risk Assessment
GP612
fl!m
Sent:
To:
Subject:
Kamboj, Sunita <skamboj@anl.gov>

RE: TENO RM Disposal in Kentucky - Risk Assessment
Thanks George for your email describing situation at two landfills in Kentucky.
Sunita Kamboj, Ph.D., CHP
Environmental Science Division
Argonne National Laboratory
9700 South Cass Avenue, Bldg. 240
Argonne, IL 60439-4847
tel: 1-630-252-5457
fax: 1-630-252.:.4624
email: skamboj@anl.gov

To: Kamboj, Sunita
9arsunita;
.Thank you for taking time from your busy schedule to discuss our situation in Kentucky (described below) regarding
disposal of TENORM waste at contained landfills which primarily receive municipal solid waste (all non-hazardous
surrounding the tracking industry, etc. that generates these wastes. Also there are firms that are now processing these
as TENORM.
Enhanced Naturally Occurring Radioactive Materials (TENORM) in North Dakota -Environmental Science Division November 1014" has been an excellent resource and guidance document as we seek to better understand the risks
The company, Advanced TENO RM Services (www.advtenorm.com) has shipped wastes to two landfills in Kentucky that
we are apparently aware of. The waste was a sludge like material that was "solidified" (mixed with solids to absorb any
The particular case we are investigating is summarized below:
- n e e d TENO RM Services, LLC shipped 35 truck containers of wastes to a landfill here in Kentucky that had the.
1
GP613
AN.ALYTICAL RE.SULTS .. RADIOCHEMISTRY

Project
Pa~r>roj~No.:
FairJ!'IOnt Brioo ~ studge PM:;1

.30ff$Q:lS~
sam pit; Fall'rrionl Bline: - SIO(fgtiJI PH
..
Cl
Lab ID: 30150265001
Ant~ny~124
EPAOOt 1
Catt-60
EPA 00.1,1
lrk!l!J.m~1 Q2
EPA 901, 1
Po~ss~m110
EPA 001.1
~durn~m
EPA 001,1
R,a'1ium~228
EPA 901~1
$ca'r:idi\.tm.4t)
EPA ooU
SilveM16M
EPA 001.1
T~tri~23~
EPA9Q1.1
Uf(llolurrt-~~
EP~..U
Cc1H.p~ed:
. 0$/08/15 09:25
Receiv~:
Q6.l.9W1515:45. Ma'tl
f2.m
Pl;iffJ
00/1W1E>f6$1 }
0.000 :t 0~56$ (1.~3)
pCilg
O:SJ1511s 1a;s1 11
o.ooo
pCitp
06t1511516~51
pCiiQ
00itl51151s:s1
1!
pci!g
1511516:51 1:
PQifg
Dri/1511f.>16'.;>1
~ifg
oij,115(1 s1 a:s1 1:
pCilg
0011511516:51
1,
1~~*392.170 (478,00Q)
c:f!fA
T;NA . . . . ... . ...
p(!ifg
Ofi/.1.511$1"6:~1
9f~3se. :i:. 17,40.fi {17 .1~

C:NAT:NA
pCilg
o.ooo .tl6.14
C:NA.T:MA
'c:K6. tt4.a.
t 0.634 (1.ti80)
:C~NAT:~A
2~~mf19:~s c11.139}
c:NAT:NA
1453,soo :aoo, 180 (M.&01
C:NA.l!NA
3o3~7.acl :t:40.774 (7 .817)

c;HAT:NA
i268 :t1~184 (1,774)
C:NA T:NA
2.$81 t 1,$67: (1.549)
.C;NAl;NA
Sincerely,
George
(jeorge P. Partritfge]r., PhD, P.E., QEP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP614
1}
'
-m:
Sent:
To:
Subject:

'Kamboj, Sunita'
RE: TENO RM Disposal in Kentucky - Risk Assessment
Glad you received it!

Thanks again for your help so much!
Have a nice afternoon!
George
From: Kamboj, Sunita [mailto:skamboj@anl.gov]

Thanks George for your email describing situation at two landfills in Kentucky.
Sunita Kamboj, Ph.D., CHP
9'ironmental Science Division
tfrgonne National Laboratory
9700 South Cass Avenue, Bldg. 240
Argonne, IL 60439-4847
tel: 1,.630-252-5457
fax: 1-630-252-4624
email: skamboj@anl.gov

To: Kamboj, Sunita

Dear Sunita;
Thank you for taking time from your busy schedule to discuss our situation in Kentucky (described below) regarding
disposal of TENO RM waste at contained landfills which primarily receive municipal solid waste (all non-hazardous
surrounding the tracking industry, etc. that generates these wastes. Also there are firms that are now processing these
as TENORM.
anced Naturally Occurring Radioactive Materials (TENORM) in North Dakota -Environmental Science Division ember 1014" has been an excellent resource and guidance document as we seek to better understand the risks
..
GP615
The company, Advanced TENO RM Services (www.advtenorm.com) has shipped wastes to two landfills in Kentucky t h a t - .
we are apparently aware of. The waste was a sludge like material that was "solidified" (mixed with solids to absorb any
Advanced TENORM Services, LLC shipped 35 truck containers of wastes to a landfill here in Kentucky that had the
AN.ALVTICAL RESULTS -RADIOCHEMISTRY

Pr~t
Fairmont Bri~ .:studge Plt GI
Piicli PQ:;ij~ Ng.:
3(11!5().25,5
Sa'm j:>le; Faimfont Bn~ -.SIU(Jge Pit.
Lab m: 30150~~001
ColkWt~~: 06/06115 09,:~5
PW's:
Si.hem;
~mtte Type:
Cl
..
R~~'. ~15 15~45
Mab
Results repoited on a "dr,y..wel~ht" baslS
Paramel:JITT;
Antfml;irt;Y~i24.
EPAlX11.f
c~t..f]t)
EeAM.1.1
lridit,i_ni-'192
EPA001.1
Pot;.1~1.lm.:40
EPA001,1
Radium~
EPA9()1.1
fYi9Juni"-228.
EPA001.1
5caooklti1-46
EPA001.1.
SilveM10M
El'AOOU
.0.000 ;ti:t674 (2A>37)
Peils;J
PS(I ~151'6:$1
0.000 : Q.56$ (1.~3}
pCiig
OSt15115 Hh51
Ct()pP :tQ.634 (1.680}

c:~i:NA
26;~9 ::1; 1,Q.@,(I (17 .1~
pCifg
0&!'1511516:~1
pCifg
OOl1511 5 1$:51 1:
14$3.soo:t 2oo;rao r+t.630}
pcilg
06/i511516:51 1:
(7~817)
~ltg;
~1~1511;t51
1.2ti [784 (1.774)

&~~A_ .. -1~-c- .2.
7"-. 1 t .549:)
pbi/g
otitt511 $16:1 1:
pQifg
061151H$16;51 1.
pt';i/9
~1911~ ts:s1
pCifg
o6/1s;151s:51'
Ci~T;NA_
. .
&NAl:NA.
CiNAT:NA ..
!""' T:tM . .
303;1:$Q:tl.774
c:NAT:NA
EPA001,1
G
T:NA
1s2~oo,t39a.110 t47tUlO())
E:P,o.l-1
g..f33~ ,17~40~ (17,78,0)

{NA:T:NA
c~ff,AT:N.~.
.. .
'
1
1J
r.;
Sincerely,
George
GP616
(jeorge P. PartridiJe Jr., PhD, P.E., QEP

~ Division of Waste Management
~~O Fair Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP617
t/lom:
Sent:
To:
Subject:

Curt;
I contacted by email this afternoon, Dr. Leong Ying who is listed as the Vice President of Advanced TENORM Services and
asked him to give me a call. Shortly after I sent my email message, Cory Hoskins called me and mentioned that Leong
had called him.
Dr. Ying apparently is in close contact with Cory Hoskins. He did not return or acknowledge my request for him to get in
touch with me.
I feel he is part of this situation and since he is on the web site, any legal action should be taken against both he and Mr.
Hoskins.
His reputation is being used by Cory to give Advance TENO RM Serv.ices a reputation as having the capabilities to manage
this waste .
.tiiJ..ry Hoskins tried his best to get me to agree with the way he was interpreting the regulations, which he apparently
ws very well, based on all he shared with me.
I did not comment on any of his statements regarding the regulations.
He also mentioned Chris and indicated that he may give him a call.
Look forward to when we can meet on this.
Thank you,
George
(jeorge P. Partriclge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP618
-om:
To:
Sent:
Subject:
Microsoft Outlook
skamboj@anl.gov
Relayed: RE: TENO RM Disposal in Kentucky - Risk Assessment
destination server:
skamboj@anl.gov (skamboj@anl.gov)
GP619
Dr. Leong Ying <leong.ying@klytec.com>

Cory Hoskins ; Robert Brenna ; Richard Yuen
RE: New Comment from KLYSTAR.com
Cc:
Subject:
Hi George,
Thank you for connecting with me .... the profile you described do indeed match me perfectly ....
.... I am currently on vacation, back Thursday. Cory Hoskins is KLYTEC business partner on TENORM issues as it relates
to hydraulic fracturing produced wastes, and he or my other KLYTEC colleagues can assist you as needed during my
absence.
Leong
Dr. Leong Ying
KL YTEC - President
leong.ying@klytec.com
Mobile: 212 203 5842
'------
------
------- -
From: george.partridqe@ky.gov [mailto:georqe.partridge@ky.gov]

To:
klystar@hotmail.com
Subject: New Comment from KLYSTAR.com
Hi Leon,
First
name:
Last
name:
George
Partridge
Address:
City:
State:
Zipcode:
Country:
-:
Email:
502-564-6716 Ext 4651

georqe.partridge@ky.gov
Comment: Are you the Leong Ying that holds a PhD in Nuclear Physics from the University of Liverpool in England and has
1
GP620
had experience working with TENORM or related analytical work. Do you know a Cory Hoskins. If so please
contact me as soon as possible! Dr. George Partridge, Kentucky Department for Environmental Protection,
Division of Waste Management.
Kind Regards
George Partridge
No virus found in this-message,

Checked by AVG - www.avg.com
Version: 2016.0.7357 I Virus Database: 4522111577 - Release Date: 02/08/16
Powered by NewzPoint 2016 J All rights reserved.
'
GP621
-m:

Pendergrass, Curt (CHFS DPH); Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney
(EEC); Hall, Karen (EEC)
RE: Vice President of Advanced TENORM Services
Sent:
To:
Cc:
Subject:
Please find correspondence from Dr. Ying that I located and contacted this afternoon by email.
From: Dr. Leong Ying [mailto:leong.ying@klytec.com]

Cc: Cory Hoskins ; Robert Brenna ; Richard Yuen
Subject: RE: New Comment from KLYSTAR.com
Hi George,
Thank you for connecting with me ....the profile you described do indeed match me perfectly ....
.... 1am currently on vacation, back Thursday. Cory Hoskins is KLYTEC business partner on TENORM issues as it relates
absence.
Leong
Dr. Leong Ying
KL YTEC - President
leong.yinq@klvtec.com
Mobile: 212 203 5842
From: george.partridge@ky.gov [mailto:george.partridge@ky.gov]

To: klystar@hotmail.com
Hi Leon,
..._.list
George
. .me:
Last
name:
Partridge
GP622
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
george. partridge@ ky. gov
Are you the Leong Ying that holds a PhD in Nuclear Physics from the University of Liverpool in England and has
Comment:
Kind Regards
George Partridge
No virus found in this message.

Version: 2016.0.7357 I Virus Database: 4522/11577 - Release Date: 02/08/16
Powered by NewzPoint 2016 I All rights reserved.
'
GP623
-m:
Sent:
To:
Subject:

RE: Special Waste Regs
Chris:
This is the other regulation I have been studying:
401 KAR 45:060. Special waste permit-by-rule.
RELATES TO: KRS 224.01, 224.10, 224.40, 224.46, 224.50, 224.99

STATUTORY AUTHORITY: KRS 224.10-100, 224.40-305, 224.50-760
NECESSITY, FUNCTION, AND CONFORMITY: KRS Chapter 224 requires the cabinet to adopt administrative regulations for the management,
processing, and disposal of wastes. KRS 224.40-305 requires persons who establish, conduct, operate, maintain or permit the use of a waste site or facility
to obtain a permit. This chapter establishes the permitting standards for special waste sites or facilities, and the standards applicable to all special waste sites
or facilities. This administrative regulation sets forth the requirements for a special waste permit-by-rule.
~ectio~.1.. Pe'"!}1it~by-rule. Notwith~ta~ding any other provision. of this .chapter{fhefoifo~ng $p~(;f~i wii~l~~~i!~{~()rJggj]jf[~~ sh~Je~ (j~~ffi~~JtQ:~:li~~{l~~
P~iti;il!sWlffi!'.\.uHB.~2w!ler;Qr;;gl);fillqrn.<!~jtj~ilj~g~fg'QRli2~[gtjrt~gi$fri:ttlon.V0tfi :th,e.c?J:iih~t, provided the operation is a practice common to the industry, is
not .in. ~iolation. of 401 f<AR. 30:Q31,. an9 does. not present a threat c>r potenti~I threatto. human health. or the enviro~ment
:m~~~:Q[iJJ~cr~ci@n~liM~ J:iifa ~n9::9~~:a:n~gf!:C!rlfiid9r:rrua :Plt~.Cfurtnii!he a.cti~~ lite 91 the i)i!.ifJh..ec1?ff i~~~~i~.9t'fi:>4g1TiQl.f:t.:C)JJ.l5i
(2) Temporary storage of special waste in piles;
(3) Injection wells used for disposal of special waste subject to 401 KAR 5:090 or in compliance with an underground injection control permit issued by
the U.S. EPA;
(4) Surface mining impoundments and other special waste surface impoundments in substantial compliance with KPDES permits;
(5) Surface impoundments that treat domestic sewage and that do not contain any industrial wastewater, or are publicly owned treatment works for the
tment of domestic sewage, if the facility is in compliance with the KP DES or NPDES permit;
(6) Disposal of coal combustion fly ash, bottom ash, and scrubber sludge in an active mining operation, if the owner or operator of the mining operation:
(a) Has a mining permit issued .under KRS Chapter 350 that includes the disposal of special waste; and
(b) Complies with the conditions of the mining permit; and
(7) Beneficial reuse of coal combustion by-products as an ingredient or substitute ingredient in the manufacturing of products, including but not limited to,
cement, concrete, paint, and plastics; antiskid material; highway base course; structural fill; blasting grit; roofing granules; and mine stabilization and
reclamation material; provided that:
(a) The utilization of coal combustion by-products does not result in the creation of a nuisance condition;
(b) Erosion and sediment control measures consistent with sound engineering practices are undertaken;
(c) The use is not within 100 feet of existing streams, 300 feet of existing drinking water wells, or floodplains or wetlands, unless permission has been
obtained from thi? appropriate regulatory agency;
(d) The generator characterizes the nonhazardous nature of the coal combustion by-products; and
(e) The generator submits to the cabinet an annual report that identifies the type and amount of waste released for reuse; the name and address of each
recipient of waste; and the specific use, if known, each recipient made of the waste.
Section 2. Noncompliances. (1) The cabinet may take any appropriate enforcement actions, including corrective action or revocation, if a special waste
permit-by-rule site or facility is not operating in substantial compliance with Section 1 of this administrative regulation.
(2) The cabinet may, at its discretion, require the owner or operator of a special waste permit-by-rule site or facility to upgrade the permit to a registered
permit-by-rule to ensure that the requirements of this chapter and the environmental performance standards of 401 KAR 30:031 are met. (18 Ky.R. 3089;
Am. 3437; eff. 6-24-92.)
Thank you for looking at this with me!

George
<george P. PartridfJe Jr.

Fair Oaks La.ne; 2nd Floor (SWB)
kfort, KY 40601
{
) 564-6716 ext. 4651
GP624
'
GP625
t/fm:
Sent:
To:
Cc:
Subject:
Attachments:

Hall, Frank (EEC)
Good Morning George,

Thank you for keeping us in the loop.
I have CC'ed Frank Hall on this email. Since this issue has escalated, Frank will need to be your point of contact.
Thanks George,
Samantha Kaiser
Division of Water
~oratory Certification Program
Fair Oaks 4th Floor

rankfort, Kentucky 40601
(502) 564-3410 ext. 4815
(502) 564-0111 Fax

Subject: FW: Laboratory Certification for Advanced Tenorm Services

Samantha;
Thank you,
George


99amantha;
1
GP626
~
tracking operations and often contain TENORM.
Corry managed.
George
'
(jeorge P. Partricfge Jr., Pfu;(, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Hi George,
I believe you left me a voicemail on Friday Jan 29 concerning a laboratory Advanced Te norm. I tried to return your call
Thank you
2
GP627
Samantha Kaiser
ision of Water
oratory Certification Program
(502) 564-3410 ext. 4815
(502) 564-0111 Fax
GP628

. .m:
Sent:
To:
Cc:
Subject:

Hall, Frank (EEC)
Samantha;
Thank you for getting back with me so quickly. We have meeting with the Radioactive Materials Section within the DPH
this morning to discuss the path forward.
I appreciate you help and guidance.
I would like to set up a meeting with Frank as soon as possible.
Thank you again for all you are doing and meeting with me.
George
t: Tuesday, February 09, 2016 7:33 AM

~
w:c: Hall, Frank (EEC)

Subject: FW: Laboratory Certification
for Advanced Tenorm Services

Thanks George,
Samantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
(502) 564-0111 Fax

: Monday, February 08, 2016 7:32 AM
1
GP629
Samantha;
Thank you,
George

Friday,-February 05; 2016 8~19 PM
-~~ Sent~
Hi Samantha;
tracking operations and often contain TENORM.
Corry managed.
'
George
(jeorge P. Partric{ge Jr., Pfid:, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP630

Hi George,
Thank you
Samantha Kaiser
Division of Water
nkfort, Ke. ntucky 40601
02) 564-3410 ext. 4815
(502) 564-0111 Fax
GP631
#am:
Sent:
To:
Subject:

Good luck! Frank is not going to be in the office today, but he may respond via email. I'm sure when he sees the email
he will be in contact with you.

Cc: Hall, Frank (EEC)
Samantha;
this morning to discuss the path forward .
predate you help and guidance.
4"
would like to set up a meeting with Frank as soon as possible .
. Thank you again for all you are doing and meeting with me.
George
Thank you.for keeping us in the loop.
Thanks George,
antha Kaiser
ronmental Scientist II
Division of Water
laboratory Certification Program
1
GP632

(502) 564-3410 ext. 4815
(502) 564-0111 Fax

Samantha;
Thank you,
George

Hi Samantha;
Thank you for meeting with me and being very generous with your time this morning to discuss the lab certification for '
Advanced TEN ROM Disposal.
We learned that Advanced TENORM Disposal also did the rad testing for waste that was sent to Green Valley Landfill in
Green ValleY, to pull all their manifests that showed out of state waste coming from counties in OH that are known for
Corry managed.
George
2
GP633
(jeorge P. PartridfJe Jr., Pfu{, P.'E., fl'EP

O Fair Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651


Hi George,
e=ink
you
.amantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
(502) 564~0111 Fax
GP634
elm:
Sent:
To:
Subject:
Attachments:

Hall, Frank (EEC)
Tracking:
Recipient
Delivery
Read
Hall, Frank (EEC)
Read: 2/9/2016 8:19 AM
Frank;
We have a meeting with the Radioactive Materials Section this morning in Frankfort at 9 am.
Would you like to join us? Three of us are going from the Division of Waste Management.
Regardless, I want the DOW involved in this situation since analytical services are involved.
Please call me as soon as you get this to (:liscuss. Please call me on my cell phone at 859-221-8843 since I will be in a
conference room this morning and away from my desk.
';rnkyou,
George

Thanks George,
Samantha Kaiser
Division of Water
Fair Oaks 4th Floor
Wl!rankfort, Kentucky 40601
(502) 564-3410 ext. 4815
(502) 564-0111 Fax
.a>
GP635
..

Samantha;
Thank you,
George

Hi Samantha;
We learned that Advanced TENO RM Disposal also did the rad testing for waste that was sent to Green Valley Landfill in '
Corry managed.
George
(jeorge P. PartridiJe Jr., Pfu;C P.T., QTP

2
GP636
200 Fair Oaks Lane;, 2nd Floor (SWB)

Frankfort, KY 40601
, . .02) 564-6716 ext. 4651

Subject: Laboratory Certification for Advanced Tenorm
Services
Hi George,
Thank you
Samantha Kaiser
vironmental Scientist II
vision of Water
laboratory Certification Program
(502} 564-3410 ext. 4815
(502} 564-0111 Fax
GP637
Subject:

Samantha,
We have a meeting with the Department of Public Health, Radioactive Materials Section at 9 am this morning.
Would you like to join us? We plan to discuss the path forward as we deal with this company.
Three of us are going and you are welcome to ride with us. The meeting is here in Frankfort at their offices.
Thanks again for all you are doing to help us.
George

.bject: RE: Laboratory Certification for Advanced Tenorm Services
. o o d luck! Frank is not going to be in the office today, but he may respond via email. I'm sure when he sees the email
he will be in contact with you.


Samantha;
this morning to discuss the path forward.
I appreciate you help and guidance.
I would like to set up a meeting with Frank as soon as possible.
Thank you again for all you are doing and meeting with me.
-~~~~

1
GP638

Thanks Georg~1
Samantha Kaiser
Division of Water
(502) 564-3410 ext. 4815
(502) 564-0111 Fax

'
Samantha;
Thank you,
George

Hi Samantha;
We learned that Advanced TENORM Disposal also did the rad testing for waste that was sent to Green Valley Landfill in
Green Valley to pull all their manifests that showed out of state waste coming from counties in OH that are known for ~
~
Cory Hoskins, the "President of Advanced TENORM Services" has also been sending out of state waste to Green Valley.
2
GP639
~ok forward to us keeping in touch as we proceed with tracking down all this illegal waste disposal operations that
Corry managed.
George
(ieorge P. PartridfJe Jr., Pfic(, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Hi George,
Thank you
Samantha Kaiser
Division of Water
Fair Oaks 4th Floor
kfort, Kentucky 40601
(502) 564-3410 ext. 4815
(502) 564-0111 Fax
.!
GP640
'm:
Sent:
To:
Cc:
Subject:

Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney (EEC); Hall,
Karen (EEC)
Briggs, Lindsey (EEC); McKinley, Matthew W (CHS-PH)
Thanks George for sharing the correspondence with Dr. Ling with us. It will be interesting to hear what Dr. Ling has to
say about the Central Midwest Compact and its ban on the disposal of out-of-compact TENORM wastes in KY. But
now that we know he is directly involved, that will give us someone else to go after should we pursue fines and
penalties. At some point we probably need to get EEC's and CHFS's lawyers involved in this matter for a legal opinion
on our ability to impose fines under the compact. The language in the statute appears pretty tight to me but an
attorney's opinion would be nice to have.
Regards,
Curt
Prohibitions -- Exemption. http://www.Irc.ky.gov/statutes/statute.aspx?id=8502
i~
(3) Naturally-occurring radioactive material (NORM) as definW !(RS 211:862(8)

s~all bethe exc111sh,eregu1ator~ responsibility of the states, exc~piihitll.Q;iJ~roii
rtK~f
nrl~~~~1i1
t:':~''l~t11i1~t~~~~~f:A~i~ftJ~k'.Yi
mm ''"otts'of(dis
osai
,
In.......................11t....,... "'
,P....... .'.:.o'f
.. ,............... " ...........
~.
are~L.o0.~"'d
nstsfenfwitli
............, .. olices
the corrtiliission.

offense.
211.862 Definitions for KRS 211.861to211.869. http://www.lrc.ky.gov/statutes/statute.aspx?id=8501

practices. Naturally occurring radioactive material does not include thenatural
~~ioactivity of rocks or soils, or background radiation, but instead tfr~rfaq
~t~~~~~~l&~~~j{[~~~j!~f~~~~wq~qglt.~}y~i,ili~n6f'.p~"by. cdntr8}1,~b1~ pfa~!i~~s
GP641

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Wel:lsite~~htt@~Hwww.Ghfs,ky.gov/dph/radioactive.htm
Dispose of ur:_wanted sources http://www.crcpd.org/StateServices/SCATR.aspx

To: Pendergrass, Curt (CHFS DPH); Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney (EEC); Hall, Karen (EEC)
Cc: Briggs, Lindsey (EEC)
Subject: RE: Vice President of Advanced TENORM Services
Please find correspondence from Dr. Ying that J located and contacted this afternoon by email.
From: Dr. Leong Ying [mailto:leong.ying@klvtec.com]

Hi George,
Thank you for connecting with me .... the profile you described do indeed match me perfectly....
absence.
Leong
Dr. Leong Ying

KLYTEC - President
leong.ying@klvtec.com
Mobile: 212 203 5842
GP642

~o:
klystar@hotmail.com
~ubject: New Comment from KLYSTAR.com
Hi Leon,
First
name:
Last
name:
George
Partridge
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
george.partridge@ky.gov
Comment:
Kind Regards
George Partridge

GP643
f/lom:
To:
Sent:
Subject:
Hall, Frank (EEC)

Read: FW: Laboratory Certification for Advanced Tenorm Services
Your message
To: Hall, Frank (EEC)
Sent: Tuesday, February 09, 2016 7:52:38 AM (UTC-05:00) Eastern Time (US & Canada)
was read on Tuesday, February 09, 2016 8:19:05 AM (UTC-05:00) Eastern Time (US & Canada) .
GP644
elm:
Sent:
To:
Cc:
Subject:
Attachments:

Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH)
RE: RE: Analytical Results Submitted by Advanced TENORM Services
Shale-Testing-Amend ment-Oac38e706276fa38ff794f22a0dflb14.pdf;
FairmontBrineRadchem.pdf; Advanced TENORM Sample Summary (2).pdf
Hello George,
Advanced TENO RM services does not have a license from our office to collect and analyze TENO RM samples or any
samples suspected of being contaminated with radioactive materials. I believe the company has an office in Ohio so I will
check with our colleagues there to see if the company has an Ohio license. Ohio actually issues licenses to companies
involved in the oil and gas industry. See the attached copy of the amended license for Shale Testing Solutions of Lisbon,
OH. Interesting both of these companies reference the same EPA method 901.1. http://www.epa.gov/homelandsecurity-research/epa-method-9011-gamma-emitting-radionuclides-drinking-water Chris actually took photos of the
Thermo RllDEye System at the ATS office in West Liberty which appeared to be set up for a laboratory type analysis with
a heavy shield in place. That system may be adequate for testing for Ra-226 and Ra-228 but I seriously doubt it. The
RllDEye was designed for hand-held operation in the field where quantification of radionuclides is not a primary concern
but rather radionuclide identification. In contrast to ATS, the laboratory employed by Waste Management to analyze
Fairmont Brine Products sludge, Pace Analytical Services is actually a NELAP certified lab with multiple offices across
US
(see https://www.pacelabs.com/about-us.html and https://www.pacelabs.com/environmental-services.html ) .
The National Environmental Laboratory Accreditation Program is the preeminent certification for any environmental
testing laboratory, including those that analyze for radionuclides. But bottom line, if Pace Analytical and ATS were
analyzing the same sample of Fairmont Brine sludge and Pace came up with 1,453.5 pCi/g Ra-226 and ATS came up 5.6
pCi/g Ra-226, I know whose numbers I would believe.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Ktztf/!J~ ... ~
....
.l.t\TloNHiiALtH
................., , , ........... .......,,.............

1
GP645

Curt;
Cory H9skins associat~_g "Yi!b ~d~v~oced lJNQRl'{I SgrvLc_~~s. The anaj_yti~~L\i\19Jtsu~rnit!ed wlthJhe_ w~ste sbipmecnts_was
I feel it is important to confirm that the waste was actually analyzed by a certified lab. When we met with Cory he
indicated he had equipment to measure the radioactivity, but he did not use it for analysis.
Advanced TENO RM Services is listed with the Division of Water as a Certified Lab for pH, TSS, and 0 & G. They are on
I am continuing to investigate our concerns regarding TE NORM and seek to do all I can to protect the personnel at the
I am available to participate in any meeting or visits as we need to. This is my highest priority.
Thanks again for all you and your group are doing!
George
<george P. PartridfJe Jr., Pfi'D, P.'E., fl'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP646
. .m:
Sent:
To:
Subject:
Weems, George (EEC)

Partridge, George (EEC); Litchfield, Arline (EEC)
Tomorrow
So are we all prepared to meet at KYDOT Region 7 offices at 7:30 or so? The Jeep is parked along the New Circle side of
the parking lot .
GP647
Subject:

Weems, George (EEC); Partridge, George (EEC)
RE: Tomorrow
Do you have an address for the parking lot? George P described it to me but I'm still not sure where it's at. I live in
Lexington so I'll be driving there myself. Thanks!
Arline Litchfield
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656
,&nt: Tuesday, February 09, 2016 11:50 AM
Subject: Tomorrow
the parking lot.
GP648
-om:
Sent:
To:
Subject:
Attachments:
Weems, George (EEC)

Litchfield, Arline (EEC); Partridge, George (EEC)
RE: Tomorrow
DOT Region 7 Parking Lot.pdf
Right across from Lexmark. If you come clockwise on New Circle you have to take the Newtown Pike exit toward 1-
64. Turn right at the Shell station (Newtown Ct) just after you drive over the New Circle bridge. Follow that road until it
ends in the DOT parking lot. If you are coming counterclockwise it's the first driveway after you pass under the Legacy
Trail bridge.
From:

To: Weems, George (EEC); Partridge, George (EEC)
Subject: RE: Tomorrow
Arline Litchfield
_.logist
9?~~!sion of Waste Management
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656
From:
Weems, George (EEC)

To: Partridge, George (EEC); Litchfield, Arline (EEC)
Subject: Tomorrow
the parking lot.
GP649
e (EEC)
RE: RE: Special Waste Regs
Subject:
Hi, George. How did the meeting go this morning?

Subject: RE: Special Waste Regs

Chris:
RELATES TO: KRS 224.01, 224.10, 224.40, 224.46, 224.50, 224.99

~btain a permit. This chapter establishes the permitting standards for special waste sites or facilities, and the standards applicable to all special waste sites
.cilities. This administrative regulation sets forth the requirements for a special waste permit-by-rule .
... Sectiori 1..
fel"lllit-by~rule. Noti,yjthstanding any. other pr()vision ()f. this chapter,;ttJE!foll<:>Wiii9~1Je~WwastS'..~ft~~:P.'J~~ilit@;.::;ha'.ll tie:c{~~iii.ec{toh~\/~/a
IJ~ri:PJ!~tb.~fah~'Jci~~LRf~QR~r~t6Efi'~Yl.i:i'!:i~l")J~~l;~fa)Ji~@jonqr:@9i::;fr~!i9riY!i!h'th~pi[il)trtet, provided the operation is a practice common to the industry, is

not in violation.C>f 401 l(AR 30:031, .a.nd .does. not present a thr~at or potential threat to hun1an hea.lth or the environm~nt
I:1J~:j:QiI!IJtQ~~Qff2rii~lit5.~7t?Jts~.ti~~9~iif@)iJU:JrUfih9'r:Ti~c{:Pftsict~Hii9!hg;acilye1ifei~fffieJ>it~Jf.UJepitJ~.::;uB1ecffQ'A'Q1;KAfil'.~QrtQi

.
the U.S. EPA;
treatment of domestic sewage, if the facility is in compliance with the KP DES or NPDES permit;
(a) Has a mining permit issued under KRS Chapter 350 that includes the disposal of special waste; and
cement, concrete, paint, and. plastics; antiskid material; highway base course; structural fill; blasting grit; roofing granules; and mine stabilization and
obtained from the appropriate regulatory agency;
(d} The generator characterizes the nonhazardous nature of the coal combustion by-products; and
permit-by-rule to ensure that the requirements of this chapter and the environmental performance standards of 401 KAR 30:031 are met. (1B Ky.R. 3089;
Am. 3437; eff. 6-24-92.)
.-rge
(jeorge P. PartrUJBe Jr.

1
GP650

200 Fair Oaks Lane; 2rid Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
'
GP651
elm:
Sent:
To:
Cc:
Subject:
Attachments:

Garrity, Patrick (EEC); Stewart, Kevin (EEC)
Hello gentlemen,
Attached is a copy of the letter provided to us by Jason Frame with the WV Radiological Health Program making mention
of the EPA Regulated Wastes Activity Form. The letter was from Fairmont Brine Processing in Fairmont, WV
(http://www.fairmontbrineprocessing.com/ ). George's comment regarding the fact that Fairmont is not actually in the
oil and gas exploration and production business but rather in the waste processing industry whose customers just so
happen to be in the oil and gas business is definitely something we all need to keep in mind.
Thanks again for your assistance in this matter and please do not hesitate to contact me if you have any questions or
comments concerning this matter.
Regards,
t Pendergrass PhD
-, erv. isor, Radioactive Materials Section
6
9Kentucky Radiation Health Branch
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Website: http:ijwww.chfs.ky.gov/dph/radioactive.htm
Vau(U~
l~f.;..,_;\::'I~
r,;tiitrnon.4\~~iLrx


1
GP652
Brine
attatchment
..

Charleston;WestVirginiaZ.53010ffice: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.

GP653
confirmed the understanding we have ofthe situation before we move forward with site visits.
-
our Assistance Director for the DWM is aware of the situation along with our Hazardous Waste Branch.
George
(jeorge P. PartridBe Jr., Pfi'D, P.T., QTP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Office: (304)356-4303
Fax: (304) 558-0524
GP654

To: Frame, Jason R
Hello Mr. Frame,
_Thar1k_you for the follow-_up_~-rnail on the Pllrported~i~positionofWV TrnoRM waste~ herein KY by Advaric:~ct
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http.://www.chfs.ky.gov/dph/radioactive.htm
Dispose of un.!"anted sources http://www.crcpd.org/StateServices/SCATR.aspx
Kc!J_
'
f~.!J.lATltJN~Jllit\:Lt~

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
GP655

To: Frame, Jason R
Hello Mr. Frame,

includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this eil since disposal of wastes containing hazardous materials including NORM/TENORM in landfills here in KY is their
ulatory purview. Ohio and Pennsylvannia both have regulations addressing the disposal of NORM/TENORM
.contaminated waste so Advanced TENORM Services might want to check with the authorities in those states to see what
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
-'in.
- - -- -"----------~ ,_.._,,==""""-"'''"""'"""'~.~~=;-~=n~__,.~,~~-=,...~"'-"""'="=-""'~"""""'"''""" __,,,"""'=--~....,,~,..,,,,.""""""""""--"""""-~'"''""'"'

5
GP656

Dr. Pendergrass,
https:Ua pp.sos. ky .gov/ftshow/(S(30ygol kfdaebcz4h poreem p4 ))/de fa u lt.aspx?path=ftsea rch&id=09042 60&ct=06&cs=99
sending fr to a Class Dian-dfill in Irvine~ kv. Mr. Fame's-qu-estlon-was in ___ -ihe'ifacking''-sTudge iri AshTa"nci,-KY~anif
ff1en
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may . ,
review, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please cantact the
GP657
t/Am:
Garrity, Patrick (EEC)

Pendergrass, Curt (CHFS DPH); Stewart, Kevin (EEC)
Sent:
To:
Cc:
Subject:
Thanks Curt. We will keep everyone posted as to our findings regarding the laboratories.
Patrick.
Patrick J. Garrity
Laboratory Certification Officer
200 Fair Oaks Lane; 4th Floor
Frankfort, KY 40601
Phone: (502)564-3410
Fax: (502) 564-2741
Email: patrick.garrity@ky.gov

~: Garrity, Patrick
(EEC); Stewart, Kevin (EEC)
!1J. Partridge, George (EEC)

.ubject:
Hello gentlemen,
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
_ - : 502-564-1492
~ail: curt.pendergrass@ky.gov
.
1
GP658

ztn~h#~
Fe.U~-f!<y
r.A~lAT!Ot{,1-1aM.TH

--subject:RE:TNORM-aisposarrri- KY-
Brine
attatchment

Office: {304)356-4303
Fax: {304) 558-0524
'

To: Frame, Jason R
Jason;
TENORM disposal.
2
GP659
, v i c e s to Kentucky that would be helpful.

Thanks again for all the time you devoted to corresponding and following up with us .
k forward to hearing from you!
.eorge
(jeorge P. Partriclge Jr., Pfi'D, P.'E., Q,TP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

ef/!!:on
R. Frame B.S. R. T. (R), Chief Radiological Health Program

3
GP660
I~
Office: (304)356-4303
Fax: (304) 558-0524
..

To: Frame, Jason R

Hello Mr. Frame,
'

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
l/f!!tllf!?llA
t/Jl~IAi"lO'i~~H~.i.T~


4
GP661
Mr. Pendergrass, .
-ologize for digging up this old email, but I don't believe I received any further response. I believe a company

Office: {304)356-4303
Fax: {304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
the disposal of any and all radioactive materials generated outSide of IL and KY anywhere in our states. This obviously
is required.
Regards,
diation Health Branch
East Main Street
lstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
5
GP662
Fax: 502-564-1492
communication, either written or implied, constitutes orshould be construed as a_ .
herein.

Cc: jason. r. frame@wv.gov
Dr. Pendergrass,
99.9 ). From Mr. Frames understanding, Advanced TEN. ORM Services L.L.C. (located in.West Liberty, KY). will be solidifying'
regards to whether or not we would allow the disposal ofTMORN from other states in the state of Kentucky or send it
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
NOTICE OF CONFIDENTIALITY: This e.mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
sender by reply email and destroy all copies of the original message.
GP663
t/lm:
Sent:
To:
Subject:

I'm still looking at the regulatory handling of TE NORM, George. Have you seen this info?
http://www.tenorm.com/regs2.htm

Chris:
RELATES TO: KRS 224.01, 224.10, 224.40, 224.46, 224.50, 224.99
cessing, and disposal of wastes. KRS 224.40-305 requires persons who establish, conduct, operate, maintain or permit the use of a waste site or facility
Section. 1. Permit-by~rule .. N()twithstandiJ"lg any ()ther provision of. this chapter, thefoiloWiri9speRi~l.:;Vas~e:.~it.e's qr fa9ili!i?$ tiaJT:l:le.ci~eiTiec:tt9 h:iive,~
i:>e'illJJfwit6pLJUli?CC?WD~r,gr:.oi:Je@2r;H~~ing~ma~E!~PPl19:~tiop9[jE!gistrtion V>fi11ltbe.c;a~ihet, provided the operation is a practice common to the industry, is
not in violation of.401 KAR 30:03~ and does not present a threat 9.r potential threat to human health or the environment:
:(1}. i9ff P!QctU~tjpij~bril}E! pi! ~riai:J~.abct oiLctrHilng :muc:t !:lits; cjuri{ig .tile actlvgfife of th.e pit, 'it thEfpij is subjE)c;t tq'4Q1 l(A.Ff 5:09Q:
the U.S. EPA;
treatment of domestic sewage, if the facility is in compliance with the KPDES or NPDES permit;
(6) Disposal of coal combustion fly ash, bottom ash, and scrubber sludge in an active mining operation, if the owner qr operator of the mining operation:
e!P.3437; eff. 6-24-92.)

George
1
GP664
(jeorge P. PartridiJe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
'
GP665
Cc:
Subject:

Weems, George (EEC)
RE: Blue Ridge Landfill
George;
As we discussed, we plan to be there at 7:30 AM in the morning.
Call me if anything changes.
George
859-221-8843

To: Litchfield, Arline (EEC); Partridge, George (EEC)
Right across from Lexmark. If you come clockwise on New Circle you have to take the Newtown Pike exit toward 1. Turn right at the Shell station (Newtown Ct) just after you drive over the New Circle bridge. Fol.low that road until it
as in the DOT parking lot. If you are coming counterclockwise it's the first driveway after you pass under the Legacy
ail bridge.
From: Litchfield, Arline (EEC)

Arline Litchfield
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656

. . .nt: Tuesday, February 09, 2016 11:50 AM
~: Partridge, George (EEC); Litchfield, Arline (EEC)
Subject: Tomorrow
GP666
elm:
Subject:
Attachments:

RE: Site Visit to Blue Ridge Landfill in Irvine, KY
Tracking:
Recipient
Delivery
Read

Hlth)
Read: 2/9/2016 3:22 PM
Sent:
To:
Chris;
We plan to meet George Weems, an inspector from the Frankfort Regional Office, Division of Waste Management at
7:30 AM in Lexington.
The vehicle we have reserved is as follows:
Vehicle: NREPC-DOW KW3077 (2006, JEEP, LIBERTY,)
Type: COMPACT SUV
License Number: KW3077
l : ' s plan on taking separate vehicles to Lexington to meet George Weems. In Lexington, we can decide what vehicles to
take from there and also how we want to handle any equipment that you and George Weems wants to bring to the site.
George Weems sent Arline and I directions and a map to where we are to meet him.
They are included in the correspondence of this email message.
I am in meetings again this afternoon.
Don't hesitate to call me on my cell phone if we need to discuss or finalize plans.
Thank you,
George
859-221-8843

Right across from Lexmark. If you come clockwise on New Circle you have to take the Newtown Pike exit toward I~ Turn right at the Shell station (Newtown Ct) just after you drive over the New Circle bridge. Follow that road until it
~ds in the DOT parking lot. If you are coming counterclockwise it's the first driveway after you pass under the Legacy
Trail bridge.
GP667


_ _ ~rl_in_e ~itch!i.~b:I
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656

Subject: Tomorrow
So are we all prepared to meet at KYDOT Region 7 offices at 7:30 or so? The Jeep is parked along the New Circle side of '
the parking lot.
GP668
--om:
To:
Sent:
Subject:
Microsoft Outlook
Delivered: RE: Site Visit to Blue Ridge Landfill in Irvine, KY

Keffer, Christopher (CHFS Rad Hlth) (Christopher.Keffer@ky.gov)
Subject: RE: Site Visit to Blue Ridge Landfill in Irvine, KY
GP669
To:
Subject:

Patrick;
Meetings all day today. I will get you the materials to you this evening or tomorrow by COB at the latest.
Thank you,
George
From: Garrity, Patrick (EEC)

To: Pendergrass, Curt (CHFS DPH); Stewart, Kevin (EEC)
9rick.
Patrick J. Garrity
Frankfort, KY 40601
Phone: (502)564-3410
Fax: (502) 564-2741

To: Garrity, Patrick (EEC); Stewart, Kevin (EEC)
Hello gentlemen,
~ks again for your assistance in this matter and please do not hesitate to contact me if you have any questions or
Regards,
1
GP670

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
HE-mail~n1rtpendergrass@ky.gov-H
Website: http://www.chfs.ky .govId ph/rad ioactive. htm

Dispose of u~anted sources http://www.crcpd.org/StateServices/SCATR.aspx

'
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
GP671

To: Frame, Jason R
Jason;
TENORM disposal.
. vices to Kentucky that would be helpful.
much detail as possible will be helpful as we review manifests, etc. at the landfills.

I know some of the above items wediscussed in our conversation but I was so floored with the news I want to be sure I

. .rge
(jeorge P. Partridge Jr., Pfi'D, P.'E., fl'EP

3
GP672

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
'

To: Frame, Jason R
Hello Mr. Frame,
TENO RM Services of Liberty, KY (http:ljadvtenorm.com/ ). We will follow up with the company's president, Cory
4
GP673

...aitucky Radiation Health Branch
~ East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
VaufU~
l'B.fii..--..Y
f{l.l,t/JA11til'~ ~H~J.TH

Mr. Pendergrass,
ologize for digging up this old email, but I don't believe I received any further response. I believe a company
erating as "Advanced TENORM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please

Office: (304)356-4303
Fax: (304) 558-0524
..
""""""""""""""""""""~-~"""""""'"""""-'"""""""""""-'""""""""'"'""""'"
To: Frame, Jason R
""
m:
GP674

Hello Mr. Frame,
includes fracking wastes generated in West Virginia. I am Cc'ing my colleagues in the Division of Solid Waste on this email sinee disposal of-wastes eentaining hazardm1s materials including N0RM/TEN0RM in landfills~hereinKYis-their--
is required.
0
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
'

Dr. Pendergrass,
back to the materials origins. I informed Mr. Frame that our office does not currently have regulation regarding TNOR4
6
GP675
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP676

Weems, George (EEC)
RE: Blue Ridge Landfill
Sent:
To:
Cc:
Subject:
Shouldn't.

Cc: Keffer, Christopher (CHFS Rad Hlth)
Subject: RE: Blue Ridge Landfill
George;
orge
-221-8843
'"'"'~~'~""' """'"'"'""~"~'"'"'~
"'
m: Weems, George (EEC)

Right across from Lexmark. If you come clockwise on New Circle you have to take the Newtown Pike exit toward 164. Turn right at the Shell station (Newtown Ct) just after you drive over the New Circle bridge. Follow that road until it
Trail bridge.

Arline Litchfield
Geologist
~d Waste Branch
~Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656
1
GP677

Subject: Tomorrow
the parking lot.
'
GP678
elm:
Sent:
To:
Cc:
Subject:

Weems, George (EEC)
RE: Blue Ridge Landfill - Sample Collection
George;
Chris Keffer plans to screen the site for radioactivity. We also have discussed checking the leachate for
radioactivity. Chris plans to conduct that sampling.
The radioactive constituents may not be that mobile in the waste, but there are numerous chemicals that may have
been concentrated in the waste from the processing of the TENORM that will show up in the soils or leachate.
I am hoping that you or Chris could take leachate and possibly soil samples to test for the presence of chemicals
including metals that may help us confirm that this waste from FBP was placed in the landfill, even if radioactivity does
not show up. The chemical profile of the leachate may show substances that are not typically found in a municipal
contained landfill leachate that we can use to confirm that waste has been placed from FBP.
Please let me know if you can collect the soil and leachate samples for testing at our labs tomorrow in addition to the
. r k Chris is doing focusing on radioactivity .
Thank you,
George
(I will also bring a list that includes chemicals that are used in this industry.)


Shouldn't.


George;
. e discussed, we plan to be there at 7:30 AM in the morning .

George
1
GP679
859-221-8843
..

- --- -- ___ _
-l'l'ailbriflge.~----

Arline Litchfield
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656
..

Subject: Tomorrow
the parking lot.
GP680

. .m:
Sent:
To:
Cc:
Subject:

Stewart, Kevin (EEC)
Okay, thanks George. We cannot contact the laboratories until we have the analytical reports. We need information off
of them to reference in the data request.
Patrick.
Patrick J. Garrity
Frankfort, KY 40601
Phone: (502)564-3410
Fax: (502) 564-2741

nt: Tuesday, Feb. ruary 09, 2016 2:58 PM
: Garrity, Patrick (EEC)
Patrick;
Meetings all day today. I will get you the materials to you this evening or tomorrow by COB at the latest.
Thank you,
George

Patrick.
Patrick J. Garrity
~ Fair Oaks Lane;. 4th Floor

. . .nkfort, KY 40601
Phone: (502) 564-3410
Fax: (502) 564-2741
1
GP681

Hello gentlemen,
P,ttac:h~d is acopy of theJetterprovide~ t() _u~ by Jason Frame with the WV Radi()l_ogkal Health ProgEa111111aki~~ 111ention
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
.
'
-~~
Kttl!!!lftm.~~
itUU.r!ATIOhlfiAr1zA!..!(i')

Brine
attatchment
GP682

:. . ..:'.f
ice of Environment.al Health Services/Radiation, Toxics and Indoor Air Division

arleston, West Virginia 25301
f.:..
/
... .
Office: {304)356-4303
F9x: (304) 558-0524
From: Partridge, George. (EEC) [mailto:George.Partridge@ky.gov]

To:. Frame, Jason R
son;
I will be joining our field inspector:s at landfills and waste sites in Eastern Kentucky to investigate our concerns regarding
TENORM disposal.

.
,,
..
.
The form or appearance of the waste when it was shipped (before solidification). VVhatdos it look like?
.
. ..
Name of company in Fairmont along with County that contracted with Advanced TENO RM S~rvices'.
Any knowledge where it was sent for solidification in Ashland, KY(?) prior to being sent the landfill.
td
confirmed the understanding we have of the situation before we move forward with site visits .
,..#
o our Assistance Director for the DWM is aware of the situation along with ol.lr Hazardous Waste Branch.
3
GP683

George
<geor9e P. PartridiJe Jr., PliV, P.'.E., Q'.EP

KYl:)ivisi90 oj Waste Ma_n~a.g~ment
Frankfort, KY 40601
(502) 564-6716 ext. 4651

,,
Jason R. frame B.S. R.T. (R), Chief Radiological Health Program

Office of Environmental Hecilth Services/Radiation, Toxics and Indoor Air Division
Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R

4
GP684
Hello Mr. Frame,
~nk you for the follow-up e-mail on the purported disposition of WV TE NORM wastes here in KY by Advanced
and Environment Cabinet Division of Waste Mahagement since they regulate landfills here in KY.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
U1>u~
IW..t..t/Jl ..~..,Y
,~:":_~~~::_

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
GP685

To: Frame, Jason R

Hello Mr. Frame,
'
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
- - - - - - - -------~~-. ___
.
From: Keffer; Christopher (CHFS Rad Hlth)
__~--~~~~.'---~"-~---~--------
,,_,

6
GP686

~bject: TNORM disposal in KY
. Pendergrass,
https:Uapp.sos.ky.gov/ftshow/(S(30ygolkfdaebcz4hporeemp4))/default.aspx?path=ftsearch&id=0904260&ct=06&cs=99
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
TICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may
lain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
1ew, use, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the
derby reply e-mail and destroy all copies of the original message.
'
GP687
-m:
Sent:
To:
Cc:
Subject:
Weems, George (EEC)

Let me contact the lab. I may have to do it at another time. If you would send that list to Michael Goss at Environmental
Services. He's the one that would have to say yea or nay on it.

Subject: RE: Blue Ridge Landfill - Sample Collection
George;
, n concentrated in the waste from the processing of the TENORM that will show up in the soils or leachate.
work Chris is doing focusing on radioactivity.
Thank you,
George

Shouldn't .
..-A><<-'' ' ' "'""'' ""'' "
~m: Partridge, George (EEC)

1
GP688

George;
George
859-221-8843

To: Litchfield, Arline (EEC); Partrioge, George (EEC)

Trail bridge.


Arline Litchfield
'
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656

Subject: Tomorrow
the parking lot.
GP689
.\
-m:
Sent:
To:
Cc:
Subject:
Weems, George (EEC)

Michael Goss said there is little they could do with it to tie it in with radio logicals and was glad I called so he could tell
me so.

George;
, n concentrated in the waste from the processing of the TENORM that will show up in the soils or leachate.
Thank you,
George
{I will also bring a list that includes chemicals that are used in this industry.)

Shouldn't.
~--~------
~m: Partridge, George (EEC)

1
GP690

George;
George
859-221-8843

Trail bridge.

Arline Litchfield
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656

Subject: Tomorrow
So are we all prepared to meet at KVDOT Region 7 offices at 7:30 or so? The Jeep is parked along the New Circle side of
the parking lot.
GP691
'
Cc:
Subject:

Weems, George (EEC)
George;
Who is Michael Goss? Please explain to me what is meant by "little they can do to tie it in with radiological." I am
looking for chemical contaminants that may be a RCRA regulated waste.
I am looking at two separate issues here.

Please let me know about the sampling!
Thank you,
George
.c:
Ant: Tuesday,
February 09, 2016 3:20 PM

Michael Goss said there is little they could do with it to tie it in with radiologicals and was glad I called so he could tell
me so.


George;
been concentrated in the waste from the processing of the TE NORM that will show up in the soils or leachate.
including metals that may help us confirm that this waste from FBP was placed in the landfill, even
dioactivity does
show up. The chemical profile of the leachate may show substances that are n. ot typically fou
municipal
tained landfill leachate that we can use to confirm that waste has been placed from FBP.
..
1
GP692
Thank you,
George

Tm-Partridge, George (EEG)
Shouldn't.

George;
'
George
859-221-8843
Trail bridge.

Arline Litchfield
Geologist
Solid Waste Branch
200 Fair Oaks Lane
2
GP693
Frankfort, KY 40601
502-564-6716 ext. 4656

Subject: Tomorrow
the parking lot.
GP694
Subject:

Weems, George (EEC)
George;
Can we collect the samples? I will work on getting a list of the chemicals we can potential check for.
I realize preservation of samples is also something we need to consider as well.
George

~t me contact the lab. I may have to do it a. t another time. If you would send that list to Michael Goss at Environmental
9-vices. He's the one that would have to say yea or nay on it.

George;
I
f/l'ankyou,
George
1
GP695

Shouldn't.

George;
George
859-221-8843
Trail bridge.
'

Arline Litchfield
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656
GP696

.....a:_Partridge, George (EEC); Litchfield, Arline (EEC)
~uject: Tomorrow
the parking lot.
GP697
t/lm:
Weems, George (EEC)

Sent:
To:
Cc:
Subject:
I'm in a bind here. I carpool and I have to plan this in five minutes and I'd like to talk to Mark Simpson but he's leaving
too.

Cc: Higginbotham, Jeri (EEC)

George;
erge
~""""'''"'"'"'"''"''''
,,_,,,,,,,,,,,,,,_,,,,,..,,,, '''""'" '''"'
" ' ' ' '""''"'""'"'"'""' " "'''"""''' '"''"""''"'"''"'"




George;
concentrated in the waste from the processing of the TENORM that will show up in the soils or leachate .
GP698
Thank you,
George

Shouldn't.

'
George;
George
859-221-8843
"'''"'''""'''""'"''''"

Trail bridge.


GP699
Arline Litchfield
Geologist
..a.A'ision of Waste Management
~rid Waste Branch
200 Fair Oaks Lane

Frankfort, KY 40601
502-564-6716 ext. 4656

Subject: Tomorrow
the parking lot.
GP700
. .m:
Sent:
To:
Cc:
Subject:
Weems, George (EEC)

And their leachate goes to the water treatment facility. They don't have to collect onsite anymore.

Cc: Higginbotham, Jeri (EEC)
George;
- :~.~~- - - . . . . ----
.rom: Weems, George (EEC)



George;
~ hoping that you or Chris could take leachate and possibly soil samples to test for the presence of chemicals
~~ding metals that may help us confirm that this waste from FBP was placed in the landfill, even if radioactivity does
1
GP701
Thank you,
George

Shouldn't.

George;
'

George
859-221-8843
""""""""""""~"""""""~"""~~
..

Trail bridge.

Arline Litchfield
Geologist
2
GP702

Solid Waste Branch
~O Fair Oaks Lane
~nkfort, KY 40601
502-564-6716 ext. 4656

Subject: Tomorrow
the parking lot .
..
3
GP703

RE: RE: Regulations
To:
Subject:
Hi, George. Let me know when you have some time to talk about the extent to which KY regulates fracking wastes.
Chris

Subject: RE: Regulations
Chris;
Here are the regulations that Dr. Curt Pendergrass send me in an email. His contact information is below was well. I will
also send your related regulations that we have in our Solid Waste Branch.
tucky Radiation Health Branch
East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website:http://www.chfs.ky.gov/dph/radioactive.htm
Dispose of un!'an!ed sources http://www.crcpd.org/StateServices/SCATR.aspx
~~

..

1
GP704

($100,000). Each day of the violation or nencomplianceshall constitute a separate
offense.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
'
GP705
Sent:
To:
Cc:
Subject:
Attachments:
Tracking:

Pendergrass, Curt (CHFS DPH); Keffer, Christopher (CHFS Rad Hlth); Briggs, Lindsey
(EEC); Kaiser, Samantha (EEC); Higginbotham, Jeri (EEC); Hendricks, Todd (EEC);
Litchfield, Arline (EEC); Stewart, Kevin (EEC)
RE: Analytical Results for TENO RM Wastes
Fairmont Brine plan.pdf; FairmontBrineRadchem.pdf; Adv TENORM Serv - Analysis for
Green Valley LF Waste.pdf; Advanced TENORM Services - Photos - 020416.pdf
Delivery
Recipient

Patrick;
Please find attached the analytical results from Advanced TENORM Services that was provided to Republic Services for
their Green Valley LF in the Ashland area. I went through all the manifests that Rodney Maze, an inspector for the DWM
working out of the Morehead Regional Office copied and sent to me following our site visit to Green Valley. I thought
there may be more but this was the only analytical results provided by Advanced TENORM Services. Cory Hoskins was
involved in additional shipments of waste to Green Valley but there were no analytical results associated with the
shipments. I question what was contained in those waste shipments.
I also attached the analytical results that Waste Management obtained on the waste from Pace Analytical that was
discussed this morning.
I will forward any additional information that may be useful to you following our site visit to Blue Ridge
Landfill tomorrow.
I also included a word document (scanned into PDF format) that contains the photos I took when we did our site visit to
Advanced TENO RM Services last week that shows their office/lab area. The two individuals in the photos other than
Chris Keffer are Cory Hoskins and his brother (from my understanding).
Thank you for all you are doing to help support this investigation!
-ge
(jeorge P. Partridj]e Jr.

1
GP706

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP707

. .m:
To:
Sent:
Subject:
Microsoft Outlook
Delivered: RE: Analytical Results for TENO RM Wastes

Subject: RE: Analytical Results for TENORM Wastes
GP708

. .m:
To:
Sent:
Subject:
Microsoft Outlook

Litchfield, Arline (EEC) (Arline.Litchfield@ky.gov)
..
1
GP709
f//*om:
To:
Sent:
Subject:
Microsoft Outlook

Kaiser, Samantha (EEC) (Samantha.Kaiser@ky.gov)
..
1
GP710
f/lom:
To:
Sent:
Subject:
Microsoft Outlook

Garrity, Patrick (EEC) (patrick.garrity@ky.gov)
..
1
GP711
--om:
To:
Sent:
Subject:
Microsoft Outlook

Hendricks, Todd (EEC) (todd.hendricks@ky.gov)
..
1
GP712
-om:
To:
Sent:
Subject:
Microsoft Outlook

Stewart, Kevin (EEC) (Kevin.Stewart@ky.gov)
,
..
GP713

. .m:
To:
Sent:
Subject:
Microsoft Outlook

GP714
~m:
Sent:
Subject:
Microsoft Outlook
Higginbotham, Jeri (EEC); Pendergrass, Curt (CHFS DPH)
Delivered: RE: Analytical Results for TE NORM Wastes

Higginbotham, Jeri (EEC) (Jeri.Higginbotham@ky.gov)
Pendergrass, Curt (CHFS DPH) (Curt.Pendergrass@ky.gov)
Subject: RE: Analytical Results for TENORM Wastes'
GP715
Attachments:

FW: Tomorrow - Blue Ridge Landfill
Tracking:
Recipient
Delivery
Re~ad

Hlth)
Read: 2/11/2016 8:32 AM
. .m:
Sent:
To:
Subject:
Chris:
This is where George Weems wanted to meet us tomorrow in Lexington. I thought we could all meet there and then
consolidate vehicles or decide how to proceed from there.
I will be first coming to my office here at 200 Fair Oaks if you would like to meet up with me.
I also am glad to have you ride with me if you would like.

Whatever works best for you.
" t give me a call to let me know what works best for you.
Thank you!
George
859-221-8843
Right across from Lexmark. If you come clockwise on New Circle you have to take the Newtown Pike exit toward 164. Turn right at the Shell station (Newtown Ct) just after you drive over the New Circle bridge. ~Follow that road until it
Trail bridge.

-ington so I'll be driving there myself. Thanks!
Arline Litchfield
1
GP716
Geologist
Solid Waste Branch
200 Fair Oaks Lane
Frankfort, KY 40601
502-564-6716 ext. 4656
From:-Weems, George (EEG) .. ..... - -

Subject: Tomorrow
the parking lot.
'
GP717
91!~m:
Sent:
Subject:
Microsoft Outlook
Delivered: FW: Tomorrow - Blue Ridge Landfill

Subject: FW: Tomorrow - Blue Ridge Landfill
GP718
e!m:
Sent:
Subject:

Read: RE: Analytical Results for TENO RM Wastes
Your message
Sent: Tuesday, February 09, 2016 5:44:47 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Tuesday, February 09, 2016 7:12:06 PM (UTC-05:00) Eastern Time (US & Canada).
GP719
-m:
To:
Sent:
Subject:

Read: RE: Analytical Results for TENORM Wastes
Your message
Subject: RE: Analytical Results for TENO RM Wastes
was read on Wednesday, February 10, 2016 7:10:34 AM (UTC-05:00) Eastern Time (US & Canada).
GP720
-m:
To:
Sent:
Subject:

Your message
To: Stewart, Kevin (EEC)
was read on Wednesday, February 10, 2016 7:13:04 AM (UTC-05:00) Eastern Time (US & Canada).
GP721
-om:
To:
Sent:
Subject:

Read: RE: Analytical Results for TE NORM Wastes
Your message
To: Garrity, Patrick (EEC)
was read on Wednesday, February 10, 2016 7:13:07 AM (UTC-05:00) Eastern Time (US & Canada) .
GP722
-m:
Sent:
To:
Cc:
Subject:
Attachments:

TENORM
TENORM Progression.docx
I can add to this if more detail is necessary.
Lindsey T. Briggs, PE
502 564 6716
GP723
TENORM Progression
George Partridge, PE, DWM; defacto DWM contact for TENO RM/NORM issues
Cyrt Pendergrass, Supervisor, Radioactive Materials Section: Cabinet for Health and Family Services
Christopher Keffer: CHFS Radiological Health
Matthew McKinley: CHFS PH
Jon Maybriar, PG, DWM; Assistant Director, Acting Field Operations Branch Manager
Rodney Maze, DWM; Morehead Region Field Inspector
George Weems, DWM; Frankfort Region Field Inspector
Lindsey Briggs, PE, DWM; Engineering Supervisor, Permit Section/SWB
Todd Hendricks, PG, DWM; Registered Geologist
Kevin Koska, VP, Compliance/Regulatory Affairs; Shale Mountain Resources

Jason Frame, Chief Radiological Health Program, State of West Virginia
Cory Hoskins: Advanced TENORM Services
Late 2014: Several e-mails between George Gilbert and Shawn Cecil concerning TENORM
6/7 /2015: TENORM Guidance Document prepared by George Partridge
January, 2016: George Partridge receives e-mails concerning waste entering Kentucky from PA and WV
1/14/16: Discuss possible TENORM disposal at Green Valley LF with Bill Chloebury, Green Valley
1/28/16: Lindsey Briggs met with Jon Maybriar (and Rodney Maze by phone) to discuss information
received concerning waste entering KY from PA and WV
2/4/16: George Partridge and Rodney Maze visit offices of Advance TENO RM Services, West Liberty, KY
and Green Valley Landfill.
2/5/2016: e-mail from Todd Hendricks to Louanna Aldridge listing parameters of concern associated
with TENORM wastes
2/9/16: George Partridge and Todd Hendricks meet with CHFS

2/10/16: George Partridge and George Weems visit Blue Ridge LF
GP724
f//Am:
To:

Subject:
RE: TENORM
Sent:
Lindsey;
I have some additional items I would like to add.
I will work on them Thursday, February
11th
and get them to you.
Thank you,
George
From~

Subject: TENORM
ti."
add to this if more detail is necessary.
502 564 6716
GP725

. .m:
To:
Sent:
Subject:

Read: RE: Analytical Results for TE NORM Wastes
Your message
was read on Thursday, February 11, 2016 8:31 :07 AM (UTC-05:00) Eastern Time (US & Canada) .
GP726
f/lm:
To:
Sent:
Subject:

Read: Tomorrow - Blue Ridge Landfill
Your message
Subject: FW: Tomorrow - Blue Ridge Landfill
Sent: Tuesday, February 09, 2016 5:51 :40 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Thursday, February 11, 2016 8:31 :57 AM (UTC-05:00} Eastern Time (US & Canada).
GP727
Sent:
Subject:

Your message
To: Litchfield, Arline (EEC)
was read on Thursday, February 11, 2016 9:06:58 AM (UTC-05:00) Eastern Time (US & Canada) .
GP728
-om:
Sent:
To:
Subject:
Attachments:
Weems, George (EEC)

Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); Litchfield, Arline (EEC)
Advanced TENORM
Hoskins photo is stock photo on google images.Jpg
You can find the Advanced TE NORM Disposal photo at the following link in Google Images. Fifth row
down. Watermarked "Shutterstock". If this can't be used as evidence, then there are no rules. Photo attached.
https://www.google.com/search?hl=en&site=imghp&tbm=isch&source=hp&biw=1184&bih=265&q=trucks+in+front+of+
chemical+tanks&og=trucks+in+front+of+chemical+tanks&gs l=img.3 ... 2232.10784.0.11304.39.17.2.20.1.0.105.1191.14j
1.15.0.... 0 ... 1ac.1.64.img .. 2.15.1055.KV6j3JzQ84o
GP729
-om:
Sent:
To:
Subject:

Accepted: TENORM Update
GP730
-om:
Sent:
To:
Subject:
Attachments:
Weems, George (EEC)

Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth); Litchfield, Arline (EEC)
Photos (real, not stock footage from Google Images) of Blue Ridge Landfill from
yesterday
photos021016 BRL.pdf
If you see any that you would like to incorporate, let me know which one(s) and I'll send the jpg to you. If you simple
want the pdf with each photo documented, let me know about that.
GP731
-om:
Sent:
To:
Subject:
Weems, George (EEC)

Is there an incident associated with the TENORM investigation?
GP732
-om:
Sent:
To:
Cc:
Subject:

Weems, George (EEC)
Briggs, Lindsey (EEC); Anderson, Danny J (EEC)
RE: Is there an incident associated with the TENORM investigation?
George;
I was a guest yesterday of the DPH for the landfill visit at Blue Ridge and also for the site visit to Advanced TEN ROM
Disposal in West Liberty.
Curt and his group are taking the lead on this investigation from what I understand. What do we need to do?
George
From:
Weems, George (EEC)
Sent: Thursday, February 11, 2016 11:26 AM

Subject: Is there an incident associated with the TENORM investigation?
GP733
-rom:
Sent:
To:
Subject:

Weems, George (EEC)
RE: Photos (real, not stock footage from Google Images) of Blue Ridge Landfill from
yesterday
George:
These are excellent photos and document everything we did yesterday!
I would like very much to have the PDF with each photo documented.
Thank you!
George
From:
Weems, George (EEC)
To: Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth); Litchfield, Arline (EEC)
Subject: Photos (real, not stock footage from Google Images) of Blue Ridge Landfill from
yesterday
. . . you see any that you would like to incorporate, let me know which one(s) and I'll send the jpg to you. If you simple
--want the pdf with each photo documented, let me know about that.
GP734
.om:
Sent:
To:
Subject:

Thursday, February 11, 2016 12.:18 PM
Chris;
I could not have been more pleased. We have their Division Director, Branch Manager, and all related individuals
participating in this investigation.
I was invited and told I could bring others as well. I got two of my coworkers interested as well as two individuals from
DOW that handles the lab certification area.
It would have been nice if someone other than just me had shown an interest in attending the meeting since I was
meeting with a group representing all levels from the Director on down to the Branch investigating this issue.
I have felt so alone on this issue that has jepordized the health of operators and individuals at the landfill site and the
surrounding community. There is a school across the street from where the trucks enter and leave and children have
been potentially exposures to airborne radioactive particulate matter.
This is a tragedy.
- e now have a radioactive waste disposal site here in Kentucky I

As of this morning, I decided to go talk to Tony Hatton. I could not have been more pleased with the position and action
he is taking. I was also informed that Daniel Cleveland has been asked to work on this. I know Daniel and I think the
world of him. It will be a pleasure to interact with him.
I have had several weeks of being totally stressed out and not sleeping well because I going at this alone.
I have enough information at this point, including records of 47 shipments of radioactive waste to Blue Ridge that is
finally getting everyone's attention.
It is tragic that some individuals may have serious health problems in future years or shortened lives due to cancer
because of the exposures that have already occurred from this mismanaged waste. What is really sad, is that
government officials from WV contacted the DWM about Advanced TENORM Services and the plans to ship this waste
to Kentucky and they go no response and then released the waste since they were ignored.
Thanks again for being a friend and looking into this for me.
George

r.._Partridge, George (EEC)
ect: RE: RE: Special Waste Regs

Hi, George. How did the meeting go this morning?
1
GP735

Chris:
RELATES TO: KRS 224.01, 224.1 O; 224.40, 224.46, 224.50, 224.99

.. . ... ~E)~ti9n
1~.F'~rm,it:by-rul~: f\jot~thstClnding ~ny ~ther provi~ion. of this chcipter,Jti~ ~R1Eii&Xn9 sppcff\l;wef.t~ JJ?:S grJ~9iliti?~'1c!lt ~e):IE!~m~~t~~~fiyf:l ~
pertn.lt~.il!ti<iHM~<i!WllEir:g@pJfi!foi:1ieYiii:l9':fu'.~Sf~.:i?pl@1[oj:i;9l'.r~g]~t[~tf9rLY,,iJh]ffg~9~filb.il.!. provided the operation is a practice common to the industry, is
not in ~iolation of 401. Kf'R 30:031 ~ and doesn~t PrE!sent a threator pote~tial threat to huma~ health or
me envimnment:
[1)~c~QICp.[QQif2tl!:?rt~5Hil:>11.'.:JillS!9~~'.liri!:9[Lffrifflri'9:ffiiJ:9lil!sj'!Iij[ing~tJ:ig~gfiy6,JitEf'9!;fne.jiiJt~ffJti~P,iti~stjjfi~tJ9'491}1<A.Fl.@1!9i
the U.S. EPA;
(7) Beneficial reuse of coal combustion by-products as an ingredient or substitute ingredient in the manufacturing of products, including but not limited t o .
cement, concrete, p.aint, and plas.tics; antiskid material; highway base course; structural fill; blasting grit; roofing granules; and mine stabilization an
,.
.1
Am. 3437; eff. 6-24-92.)

George
(jeorge P. Partricfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP736
GP737
-m:
Sent:
To:
Subject:

Thursday, February 11, 2016 1.2:21 PM
Chris;
Yes, thanks for reminding of the excellent resource it is.
George
Subject: RE: RE: Special Waste Regs
I'm still looking at the regulatory handling of TENORM, George. Have you seen this info?
http:ljwww.tenorm.com/regs2.htm
-- .,, ................,..,,,..,,,,"'..'''"'"''''- , , , , , , , , , , , , ,

nt: Monday, February 08, 2016 6:02 PM

Chris:
RELATES TO: KRS 224.01, 224.10, 224.40, 224.46, 224.50, 224.99

processing, and disposal of wastes. KRS 2.24.40-305 requires persons who establish, conduct, operate, maintain or permit the use of a waste site or facility
. . Secti.on 1.:. Pl:Jrmit:~~-~ul~; [\Jotwithstanding any other. provision of. this chapter, the following special Wast(sites qr fa9iJiije shal[be (l~ern~d tq Jll'iYel
PEirmiLWltllQ\.IUl1_gYJrir10Lc)J:>er,at~ill~\'.iri9 irfa(le applic~tiori gr_ registration i,\.ith th,e cabinet, provided the operation is a practice common to the industry, is
not in vi~lation of 401. KAR ~0:031 ~ an~ d?~s not present .Ii threat orpotential threat to humanhealth or the environm~nt:
!'f) ~ .pTI.p'rgp_uc::ti.911'.firiil~ pits~a6i:t 9a~'aocf.9n
i:riQ(lpi~s, t;1urlng ille agtive life qfttie pit, it the pit is subjecftp 4o1.AAB 5:o9o;
the U.S. EPA;
(4) Surface mining impoundments and other special waste surface impoundments in substantial compliance with KP DES permits;
treatment of domestic sewage, if the facility is in compliance with the KP DES or NP DES permit;
Complies with the conditions of the mining permit; and
Beneficial reuse of coal combustion by-products as an ingredient or substitute ingredient in the manufacturing of products, including but not limited to,
c
nt, concrete, paint, and plastics; antiskid material; highway base course; structural fill; blasting grit; roofing granules; and mine stabilization and
Clliiiin9
.ti
GP738
(d} The generator characterizes the nonhazardous nature of the coal combustion by-products; and
Am. 3437; eff. 6-24-92.)

George
(jeor9e P. Partrid{Je Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP739
-m:
Sent:
To:
Subject:

Hi Curt;
I want to thank you for the email you sent to Patrick and Kevin.
FBP may be recovering the water from Fracking Operations, but it is concentrating the radioactive materials and
chemicals that are present. As a result they are creating a new level of "TENORM" waste that has not been addressed to
date. We need to investigate all the chemical constituents, those that are radioactive as well as those that are not. I
question if the intent of the waste exclusion for the O&G industry is applicable since this is a waste stream that is
generated by another company or industry that serves them and produces waste sludge, etc. that has characteristics
that are so much more hazardous than the initial waste stream produced from the tracking operation.
It was a pleasure to join Chris Keffer yesterday for the site visit to Blue Ridge. Chris spent hours surveying the surface of
the cell where the waste from FBP was placed. It was very cold and windy with snow blowing and even moisture in our
beards freezing. No one could have worked harder or done a more thorough job than <.::hris did. Also the positive spirit
and the way he approaches his work, you would have thought we were working under ideal conditions in nice
weather. It is a pleasure to know and join Chris. Please extend my appreciation again to him.
- m so grateful and appreciative for all you and your Branch/Division is doing to address the issue of radioactive waste
disposal at our landfills where workers do not have the training or PPE to handle it and at landfills that were never
designed to contain it.
Thanks again for all your group is doing.
George
(jeor9e P. Partricloe Jr., Pfi'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
om: Garrity, Patrick (EEC)

t: Tuesday, February 09, 2016 12:45 PM
Pendergrass, Curt (CHFS DPH); Stewart, Kevin (EEC)
- Cc:
- Partridge, George (EEC)
1
GP740
Patrick.
Patrick J. Garrity
Frankfort, KY 40601
Phone: (502) 564-3410
Fax: (502) 564-2741

Hello gentlemen,
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
"VnnfU
~;~ ........
fi>\?ll/.\'fmH

2
GP741

Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.
- u c h detail as possible will be helpful as we review manifests, etc. at the landfills.
GP742

George


Office: (304)356-4303
Fax: {304) 558-0524

To: Frame, Jason R
4
GP743
Hello Mr. Frame,

. n k you for the follow-up e-mail on the purported disposition of WV TENO RM wastes here in KY by Advanced
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
fJC_""_~~~r~-- ------------ --- ----- . . -- ----------- --------------


Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524
GP744


To: Frame, Jason R

Hello Mr. Frame,
....
contaminated waste so Advanced TENORM Services might want to check with the authorities in those states to see what ~
is required.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
~--~--. .~-~~~~-m~--~~~-~-'"~-~--.-.---~---
-------

6
GP745

. . Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
lain confidential information exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any
der by reply e-mail and destroy all copies of the original message.
GP746
-m:
Sent:
To:
Subject:

Curt;
Thank you!
George

Hello gentlemen,
t : www.fairmontbrine rocessin .com ). George's comment regarding the fact that Fairmont is not actually in the
and gas exploration and production business but rather in the waste processing industry whose customers just so
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
.~.~
1\.lZLIM~:!I
-JATlti:f'l.M~\lTH

1
GP747

Brine
attatchment

Office of Environmental Health Services/Radiation, Toxics and Indoor .('\ir Division
Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Jason;
TENORM disposal.
2
GP748
Number and type of trucks/ volume, etc. of.the wastes .

Thanks again for all the time you devoted to corresponding and following up with us ..
George
(jeorge P. Partridj]e Jr., Pfi1J, P.'E., Q'EP

Frankfort, KY 40601
, 2 ) 564-6716 ext. 4651


Office: (304)356-4303
Fax: (304) 558-0524
GP749


To: Frame, Jason R

Hello Mr. Frame,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
~~


Mr. Pendergrass,
GP750
- i s e on this issue. Thanks

Office: (304)356-4303
Fax: (304) 558-0524
m:

.
Frame, Jason R
Hello Mr. Frame,

is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
~pho.ne: 502-564-3700 ext. 4183
. .: 502-564-1492
.
5
GP751
herein.

Dr. Pendergrass,
in place and that each landfill may have their own limits on what they except or turn away in regards to radiation levels.,.
.
(iason.r.frame@wv.gov ).
'
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
GP752
e!.~=
To:
Cc:
Subject:
Weems, George (EEC)

Briggs, Lindsey (EEC); Anderson, Danny J (EEC)
RE: Is there an incident associated with the TENORM investigation?
I'd say nothing then until they request something from us. So there is no incident associated with this? If not I'll just
leave the incident box blank on the Work Hazard Assessment.

Cc: Briggs, Lindsey (EEC); Anderson, Danny J (EEC)
Subject: RE: Is there an incident associated with the TENORM investigation?

George;
I was a guest yesterday of the DPH for the landfill visit at Blue Ridge and also for the site visit to Advanced TEN ROM
Disposal in West Liberty.
Curt and his group are taking the lead on this investigation from what I understand. What do we need to do?
fl.orge

Subject: Is there an incident associated with the TENORM investigation?
..
1
GP753
-m:
Sent:
To:
Subject:
Weems, George (EEC)

yesterday
No; jpg. You got the pdfs of the powerpoint.

Subject: RE: Photos (real, not stock footage from Google Images) of Blue Ridge Landfill from yesterday
George:
Thank you!
..
...Jtorge
,,,"""""""'""'""""'"""""~'"""

Subject: Photos (real, not stock footage from Google Images) of Blue Ridge Landfill from yesterday
If you see any tlfat you would like to incorporate, let me know which one(s) and I'll send the jpg to you. If you simple
GP754
-m:
Sent:
To:
Subject:

Hendricks, Todd (EEC); Litchfield, Arline (EEC); Partridge, George (EEC); Nielsen, Jamie
(EEC); Razavi, Mohammad (EEC)
Next Week
Big Run:
renewal RTC- unknown -draft by 2-19
draft permit (multiple actions)-Jamie by 2-19
renewal RTC - meeting to finalize (??) by 2/19
Central Kentucky: HEX response to NOD - Jamie, Todd, Mohammad (surface water drainage), and George (liner design)
by 2-24
Bluegrass Containment: GWAR NOD -Arline and Kevin P by 2-19
Hardin County Meeting - 2/16; Lindsey, Mohammad, Arline, Danny

.ndleton County Meeting - 2/19; Danny, George, Mohammad, Jamie, Todd
Notify me if I am missing anything or we need to discuss.
502 564 6716
GP755
fJ//Am:
Sent:
To:
Subject:

George, sorry I couldn't take your call. I'm under the gun to get a document finished and filed.
A couple of days ago, I spent a fair amount of time looking at CERCLA, RCRA, and Kentucky law on TE NORM (to the
extent there is any) and whether it falls into several regulatory schemes. There are a couple of provisions that DWM
could use to act here, but clearly CHFS has the primary regulatory role in this area. I have talked at some length to
Daniel, and I think he is on top of the regulatory framework and the relative responsibilities of DWM and CHFS. So, I
think DWM is getting good advice here without a doubt in the form of Daniel.
Let's get out for lunch next week!
c

~ris;

George

I'm still looking at the regulatory handling of TENO RM, George. Have you seen this info?
http://www.tenorm.com/regs2.htm

Chris:
. s is the other regulation I have been studying:
RELATES TO: KRS 224.01, 224.10, 224.40, 224.46, 224.50, 224.99
GP756

to obtain a permit. This chapter establishes the permitting standards for special waste .s.ites .o.r fa.c.i.lities. . a.n.d. t. h.e sta.nd..ards a.p..plic.ab.le.. to. al.I spe.cia.I waste .sit.e.~
..
~
qr
Section 1. .Permit-by-rule. Notwithstanding any at.her pr()visionof. this. chapter; tbe t9llowi69 speqi~J}Na$te ~ites
faciltlies;sll~!l_t;Jii de~md tg h!\f~.-,c!
j:l~rrl11Fx;lij!i(i.uft6~ QWJ"!S:t.9r:"Zo-pr~foi_hVing rtia~!'l aJ'.lpUcatiqr) or regi~tr~tiC>n wffti:th_c!t;Jir1~~. provided the operation is a practice common to the industry, is
not in ~iolation of 401 l(A~ 30:031, and. d,oes not present a th.rea.t or potential threat. to human. health or the environment:. . .. .. . . ...
{1) }Qif Rr:.oill.Jction ~rjn~~iJl!s'~:rfcfgg{~nciiJii;tfrf11169 rjJyd p@,(j~ring the i3,ctii/E?)if~gHfl~:i>I1~:1! Jhe.plt is subject to-4oj .19:\B 5:0~Qi
the U.S. EPA;
(5) Surface impoundments that treat domestic sewage and that do not contain anyindustrial wastewater, or are publicly owned treatment works for the
treatment of domestic sewage, if the facility is in compliance with the KP DES or NP DES permit;
(7) Beneficial reuse of coal combustion by-products as an ingredient or substitute ingredient in the-manufacturing of products, including but not limited to,
Am. 3437; eff. 6-24-92.)
'
George
<geor9e 1'. PartridiJe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP757
'
t/lm:
Sent:
To:
Subject:

Chris;
Thank you! Daniel is joy to know and work with.
Thank your both,
Lunch next week sounds great!
George


.orge, sorry I couldn't take your call. I'm under the gun to get a document finished and filed .
couple of days ago, I spent a fair amount of time looking at CERCLA, RCRA, and Kentucky law on TE NORM (to the
extent there is any) and whether it falls into several regulatory schemes. There are a couple of provisions that DWM
could use to act here, but clearly CHFS has the primary regulatory role in this area. I have talked at some length to
Daniel, and I think he is on top of the regulatory framework and the relative responsibilities of DWM and CHFS. So, I
think DWM is getting good advice here without a doubt in the form of Daniel.
Let's get out for lunch next week!
c


Chris;
George

~nt: Tuesday, February 09, 2016 12:57 PM
9!'5=
I'm still looking at the regulatory handling of TENO RM, George. Have you seen this info?
1
GP758
http:Uwww.tenorm.com/regs2. htm

Chris:
RELATES TO: KRS 224.01, 224.10, 224.40, 224.46, 224.50, 224.99

Section 1:.. Permit-by-rule; Notwithstanding Ciny other pr?vision of this. chapter, lhefoll6Wirig~speic:;iaJ W:aste sites 6rfac:;iJitis ~t1t:i1rn~ c:J~.~me.ct't9'. h!l-v~ ~
iJermi(wlihoU:t tt1iow~eror>9per~tor~a\itng'.Qi~d1f~ppli~i:\ti9nofregi!)tration W)ththe<iabirjet, provided the operation is a practice common to the industry, is
not in violation of 401. KAR 30:031, and does not present a .threat or potential threat to human health or t.he environment:
(1) ;;pi1prociuc:tl2nl:foh~Pits ci6\l~~~.~b~oil ~rllJin9'ri:i~~pits, f!~rifig the.active life the pit, ifttie pit is sulJjecho/i(J1 KA.Fl :o~p1
the U.S. EPA;
(5) Surface impoundments that treat domestic sewage and that do not contain any industrial wastewater, or are publicly owned treatment works for t h '
at
Am. 3437; eff. 6-24-92.)

George
(jeor9e 'P. 'PartridfJe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP759
GP760
-m:
Sent:
To:
Subject:
Weems, George (EEC)

yesterday
Just re-read this, you want the photos label by me instead of you incorporating them in a photo doc by you .. Ok. I'll just
do it as my photo page for the SW inspection.

George:
Thank you!
fl.orge

GP761

m:
Sent:
To:
Subject:

Weems, George (EEC)
yesterday
George;
That sounds great.
Since Jon Maybriar is having us follow the initiative of Curt Pendergrass and his group and officially we are their guest at
their planned visits, I did not know how this should be documented on the DWM end.
Thanks again for joining us and all you are doing.
George

,bject: RE: Photos (real, not stock footage from Google Images) of Blue Ridge Landfill from yesterday
.Just re-read this, you want the photos label by me instead of you incorporating them in a photo doc by you .. Ok. I'll just

George:
Thank you!
George

~1 ou see any that you would like to incorporate, let me know which one(s) and I'll send the jpg to you.
~nt the pdf with each photo documented, let me know about that.
1 .
If you simple
GP762
-om:
Sent:
To:
Subject:

Weems, George (EEC)
RE: Advanced TENORM
George;
Thank you!
George

To: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); Litchfield, Arline (EEC)
Subject: Advanced TENORM
You can find the Advanced TENO RM Disposal photo at the following link in Google Images. Fifth row
https:Uwww.google.com/search?hl=en&site=imghp&tbm=isch&source=hp&biw=1184&bih=265&q=trucks+in+front+of+
hemical+tanks&o =trucks+in+front+of+chemical+tanks& s l=im .3 ... 2232.10784.0.11304.39.17.2.20.1.0.105.1191.14'
5.0 .... 0 ... lac.1.64.im .. 2.15.1055.KV6'3Jz 840
GP763
-m:
Sent:
To:
Subject:
Weems, George (EEC)

RE: Advanced TENORM
Here is an easier link: http://www.shutterstock.com/pic.mhtml?id=81208441&src=id

It goes right to the site page to download it.

Subject: RE: Advanced TENORM

George;
Thank you!
George
, ~om: Weems, George (EEC)
nt: Thursday, February 11, 2016 9:16 AM

o: Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); Litchfield, Arline (EEC)
You can find the Advanced TENORM Disposal photo at the following link in Google Images. Fifth row
chemical+tanks&oq=trucks+in+front+of+chemical+tanks&gs l=img.3 ... 2232.10784.0.11304.39.17.2.20.1.0.105.1191.14j
1.15.0.... 0 ... 1ac.1.64.img .. 2.15.1055.KV6j3JzQ84o
GP764
~-------
----
.I
.m:
Sent:
To:
Subject:
Weems, George (EEC)

RE: Photos (reat not stock footage from Google Images) of Blue Ridge Landfill from
yesterday
I was mainly there to do my inspection; there was nothing that said I couldn't assist a bit. And it always helps to have
someone who knows the site to some degree to smooth the path so to speak. If I hadn't been there, Billy might have
been a bit more uncomfortable. He was a bit nervous at the very first though.

George;
That sounds great.
Since Jon Maybriar is having us follow the initiative of Curt Pendergrass and his group and officially we are their guest at
_.eir planned visits, I did not know how this should be documented on the DWM end.
Sanks again for joining us and all you are doing.
George

Just re-read this, you want the photos label by me instead of you incorporating them in a photo doc by you .. Ok. I'll just

George:
I would like very much to have the PDF with each photo documented .
ankyou!
George
1
GP765

'
GP766
fJ/Am:
Sent:
To:
Subject:

Curt;
Dr. Ling has used his reputation and skills to support the activities of Advanced TENO RM Services. It appears that
Cory Hoskins has two businesses incorporated out of his home, BES LLC and Advanced TENO RM Services. He appears
to be using Advanced TENO RM Services to attract business from out of state for companies that are searching for an
attractive cost solution to their TENO RM disposal needs. He is using the BES LLC company name and signing off as
the generator of the wastes on the correspondence with the landfills where he ships that waste. That does two
things for him: 1) TENO RM is not mentioned in the correspondence or the name of the company that the landfill or
waste management company sees and 2) being the generator the landfill has the impression that they are receiving
waste that was generated in-state and not regulated, so they feel comfortable accepting it.
I have never seen such misrepresentation in the environmental field in my career by individuals t.hat know the
regulations so well (Cory Hoskins) and an individual such as Dr. Ling who is so knowledgeable from a technical
perspective and aware of the regulations at a national level. He would also know the seriousness of disposing of the
waste at a landfill where the workers are not using PPE or are trained on this type of waste.
1
#._,.
Ling also should know the safety precautions one would should take when handling or sampling this type of
waste.
I hope that legal action will be taken against Cory Hoskins and his companies. We not only need to stop him, but also
handle this in a way that lets others know the consequences of ignoring the regulations when knowingly they are
violated. Most of all his actions are jeopardizing the future well-being of those that are exposed to tbis waste,
particularly from an inhalation pathway.
My understanding from our Division of Waste Management is that we have no regulatory authority for this type of
waste and all enforcement would need to come from your Cabinet. At the same time today I learned we do plan to
take action to let our waste management facilities around the state know about this waste that is being shipped and
disposed of at their facilities.
l want to do all I can to support the work that you and your Section is doing to safely manage and regulate TENO RM.
Thanks again for including me in the meeting and for all that Chris has done to help educated us about TENO RM and
radiation safety as well as the site visits he has conducted.
Geroge
(jeorge 'P. 'Partridjje Jr.

1
..Ji.Y Division of Waste Management

~00

Frankfort, KY 40601
(502) 564-6716 ext. 4651
1
GP767

To: Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth); Maze, Rodney (EEC); Hall, Karen (EEC)
Cc: Briggs, Lindsey (EEC); McKinley, Matthew W (CHS-PH)
say about the Central Midwest Compact and its ban on the disposal of out-of-compact TENO RM wastes in KY. But
'
Regards,
Curt

shall ~e. t.he e:x~l~siv~ ~e~ul~tory..resp.?nsi?ility.otthe states, ~~c~ptthW~~~p~r;~9ii
il~l!l1~it::,:c;:111~&!ttl~if!f~~JtkY:

offense.
2
GP768
~ ~. . ~
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9'!1d10activ1ty
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but
mstead
ref(irS
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u r.arocks
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ria ..l .. .e.sn
o.t.!nc
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t.ural
tii<!tf~~s\v~9s ra~lsj~~ti\rHy is t~shnol6gifaflly.enhariyed bycontroliapfo practises
r<2J1~y pasf liHm~npfastfoes);

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492


Hi George,
- h a n k you for connecting with me .... the profile you described do indeed match me perfectly ....
GP769
absence.
Leong
Dr. Leong Ying

KL YTEC - President
leong.ying@klvtec.com
Mobile: 212 203 5842

Hi Leon,
First
name:
Last
name:
George
Partridge
'
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
qeorge.partridge@kV.gov
Comment:
Kind Regards
George Partridge

Checked by AVG - www .avg.com
4
GP770
~=
To:
Subject:

Weems, George (EEC)
RE: Advanced TENORM
George;
Thanks so much for sending this!
George
Sent: Thursday, February 11, 2016 2: 10 PM


om: Partridge, George (EEC)
nt: Thursday, February 11, 2016 2:03 PM

: Weems, George (EEC)
- Subject: RE: Advanced TENORM

George;
Thank you!
George


You can find the Advanced TENO RM Disposal photo at the following link in Google Images. Fifth row
chemical+tanks&oq=trucks+in+front+of+chemical+tanks&gs l=img.3 .. .2232.10784.0.11304.39.17.2.20.1.0.105.1191.14j
1.15.0.... 0 ... 1ac.1.64.img.. 2.15.1055.KV6j3JzQ84o
GP771
e!~
To:
Subject:
Weems, George (EEC)

RE: Advanced TENORM
If this can't prove he's a scofflaw, nothing will.


George;
Thanks so much for sending this!
George

l:.bjed: RE: Advanced TENORM



George;
Thank you!
George


down. Watermarked "Shutterstock". If this can't be used as evidence, then there are no rules. Photo attached .
tps://www.google.com/search?hl=en&site=imghp&tbm=isch&source=hp&biw=1184&bih=265&q=trucks+in+front+of+
chemical+tanks&oq=trucks+in+front+of+chemical+tanks&gs l=img.3 ... 2232.10784.0.11304.39.17.2.20.1.0.105.1191.14j
1.15.0.... 0 ... 1ac.1.64.img.. 2.15.1055.KV6j3JzQ84o
1
GP772
f/Am:
Sent:
To:
Subject:

FW: Advanced TENORM
Curt;
George Weems sent this to me today. It is the photo that Cory Hoskins is using on the company website for Advanced
TENORM Services. It appears to be copyrighted material.
I plan to look further into this.
I will let you know what I learn.
I question if there are legal implications regarding what Cory Hoskins has done in terms of his use of the Internet and
resources from the Internet.
Thanks again for everything you are doing!
George
_.WM
Com: Weems, George (EEC)


George;
Thank you!
George

Sent: Thursday, February 11,
2016 9: 16 AM
Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); Litchfield, Arline (EEC)
ject: Advanced TENORM
1
GP773
--m:
Sent:
To:
Subject:
Attachments:
Aldridge, Tabitha (EEC)

WW Application and QAP
KY08061 WW Application 2015.pdf; KY08061 WW QAP.pdf
GP774
f#om:
Sent:
To:
Cc:
Subject:
Attachments:

Anderson, Danny J (EEC); Briggs, Lindsey (EEC); Keffer, Christopher (CHFS Rad Hlth);
Litchfield, Arline (EEC); Hendricks, Todd (EEC); Aldridge, Tabitha (EEC); Higginbotham,
Jeri (EEC); Garrity, Patrick (EEC); Stewart, Kevin (EEC); Maze, Rodney (EEC); Weems,
George (EEC)
FW: Advanced TENORM Website Photos
Shutterstock - Photos for Purchase.pdf; SH.UTTERSTOCK License for Customer.docx
Curt:
As I shared with you previously, It appears that Advanced TENORM Services uses the company website to attract
TENORM disposal business to Kentucky from other states and then manages or using the other company name they
have for the transport, shipment, and disposal with the landfill and its management. I am concerned about the
misrepresentation of the company on the website.
George Weems, our inspector with the DWM, located the photo for sale on "Shutterstock" by an artist and is listed as
"Chemical Industry, Storage Tank and Tanker Truck in Industrial Plant."
~ve attached the source of the photo posted on the website at Shutterstock as an attachment with also a screen
9ture of the license agreement by Shutterstock. I have highlighted the section of the license agreement which I
.uestion if Advanced TEN ROM Services violated by using the photo to misrepresent the capabilities of their company for
transport and management of TENORM.
Please pass this information on to the legal staff that is investigating this case for CHFS-DPH.
Thank you,
George
George P. Partridge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651

1
GP775

Here is an easier link: http://www.shutterstock.com/pic.mhtml?id=81208441&src==id


Subject: RE: AdvallC:ed TENORM
George;
Thank you!
George
Sent: Thursday, February 11, 2016 9: 16 AM

chemical+tanks&og=trucks+in+front+of+chemical+tanks&gs l=img.3 ... 2232.10784.0.11304.39.17.2.20.1.0.105.1191.14j
1.15.0.... o... 1ac.1.64.img . 2.15.1055.KV6j3JzQ84o
GP776
-om:
Sent:
To:
Cc:
Subject:
Attachments:

Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Keffer, Christopher (CHFS Rad Hlth)
FW: WW Application and QAP for Advanced TENORM Services
KY08061 WW Application 2015.pdf; KY08061 WW QAP.pdf; Advanced TENORM Services
- Photos - 020416.pdf .
Curt;
I have attached the wastewater lab certification application and materials that were submitted to the DOW where he
represents having a highly equipped well established laboratory located at his home address.
I have also attached the photos in a document that I prepared from our site visit that show the laboratory he has located
in the Morgan County Public Library where there appears to be no sink or running water, only an partitioned office area
with the door labeled "B" on the front, no company name. I do not see how he could be running a laboratory from this
location, unless he is using the public restrooms at the library for washing his hands and cleaning equipment etc., which
would put the office employees and public users at risk.
I am sending this to your attention since it includes other names associated with Advanced TENO RM Services that may
misrepresenting themselves to potential customers seeking a firm that can manage and dispose of their TENO RM
st es.
Please forward this information as you see appropriate to your legal staff at CHFS-DPH.
'
Thank you,
George
(jeorge P. Partrirfge Jr., Pfi'D, P.'E.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
Jil&m: Aldridge, Tabitha (EEC)
t : Thursday, February 11, 2016 3:24 PM

Subject: WW Application and QAP
1
GP777
111!:,~
To:
Subject:

Aldridge, Tabitha (EEC)
RE: WW Application and QAP
Tabitha;
Thank you!
George
From: Aldridge, Tabitha (EEC)
,,
GP778
f/lm:
Sent:
To:
Cc:
Subject:
Attachments:

Maze, Rodney (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Garrity, Patrick
(EEC); Stewart, Kevin (EEC)
Adv TENORM Serv - Analysis for Green Valley LF Waste.pdf
Hello Curt;
As we noted and mentioned on these analyses, LY's initials are shown on the "Sample Analyte Count." As I recall from
what Patrick Garrity from the Division of Water (DOW) shared with us in our meeting in your offices, we can ask for the
supporting documentation for the analytical results that were submitted to Republic Services for the Green Valley
Landfill facility. That would help us understand where the results were obtained, the location of the lab or facility, and
confirm their certification.
You may have already investigated this, if not I feel this is something we should pursue.
Please share your thoughts! I want to understand this situation better and identify all the individuals involved. The
initials are the same as the "Vice President" of Advanced TENORM Services .
..-9ri concerned that we may not truly know what the characteristics are of the waste that have been disposed of at
. e e n Valley LF operated by Republic Services since the analytical results were provided by Advance TENORM Services.
What should be out next step?
Look forward to hearing from you!'
George
<jeorge 'P. 'PartridiJe Jr., 'PfiV, 'P.'E., fl'E'P

Frankfort, KY 40601
(502) 564-6716 ext. 4651
~""""''"'"'-'"'''''"''''"'""'"''"''"'"'"''''~""'"'''"'"'"''"-'""'"""""'""""'"'""'''""''"""""""'"'''"'""'""'""""'"'"''""'"'"""'''''''' ""'~'""'""''''''""'"''""""""'"""''"""'""""'"

IWn: Pendergrass, Curt (CHFS DPH)

1
GP779
Cc: Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH)
Subject: RE: RE: Analytical Results Submitted by Advanced TENORM Services

Hello George,
Advanced TENORM services does not have a license from our office to collect and analyze TENORM samples or any
OH. Interesting both ofthese companies reference the same EPA method 901.1. http:/Jwww.epa.gov/homelandsecurity~research/epa-method-9oii ~gamma-emTffing-radionudldes-drlnKlng~water Chris actually fook pliofosof then
this Fairmont Brine Products sludge, Pace Analytical Services is actually a NELAP certified lab with multiple offices across
the US (see https://www.pacelabs.com/about-us.html and https://www.pacelabs.com/environmental-services.html ).
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
l<ttltuiti~J
fU\trtATl(.)<i~H~Ttt
From:
Partridge~
George (EEC)
Curt;
Cory Hoskins associated with Advanced TENO RM Services. The analytical work submitted with the waste shipments was
2
GP780
-esented, I do not understand the need to ship the waste to Kentucky at a higher cost to the company.
.
available to participate in any meeting or visits as we need to. This is my highest priority.
George
GP781
-m:
Sent:
To:
Subject:
Attachments:
Maze, Rodney (EEC)

Re: Analytical Results Submitted by Advanced TENORM Services
imageOOl.gif; image002.jpg
George,
Do you have the email from Curt where he advised Cory it was not acceptable to dispose of TENO RM waste from outside
the state of KY.
Thanks
Rodney
Rodney Maze
Hello Curt;
As we noted and mentioned on these analyses, LY's initials are shown on the "Sample Analyte
Count." As I recall from what Patrick Garrity from the Division of Water (DOW) shared with us in our
meeting in your offices, we can ask for the supporting documentation for the analytical results that were
submitted to Republic Services for the Green Valley Landfill facility. That would help us understand
where the results were obtained, the location of the lab or facility, and confirm their certification.
Please share your thoughts! I want to understand this situation better and identify all the individuals
involved. The initials are the same as the "Vice President" of Advanced TENO RM Services.
I am concerned that we may not truly know what the characteristics are of the waste that have been
disposed of at Green Valley LF operated by Republic Services since the analytical results were provided
by Advance TENORM Services.
George
(jeorge P. Partritfee Jr., Pfi'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP782

Sent:Tuesday, Fet>ru~uy Q9,
2016 S:4Q AM

Hello George,
Advanced TE NORM services does not have a license from our office to collect and analyze TENO RM
samples or any samples suspected of being contaminated with radioactive materials. I believe the
company has an office in Ohio so I will check with our colleagues there to see if the company has an
Ohio license. Ohio actually issues licenses to companies involved in the oil and gas industry. See the
attached copy of the amended license for Shale Testing Solutions of Lisbon, OH. Interesting both of
these companies reference the same EPA method 901.1. http://www.epa.gov/homeland-securityresearch/epa-method-9011-gamma-emitting-radionuclides-drinking-water Chris actually took photos of
the Thermo RllDEye System at the ATS office in West Liberty which appeared to be set up for a
laboratory type analysis with a heavy shield in place. That system may be adequate for testing for Ra226 and Ra-228 but I seriously doubt it. The RllDEye was designed for hand-held operation in the field
where quantification of radionuclides is not a primary concern but rather radionuclide identification. In
contrast to ATS, the laboratory employed by Waste Management to analyze this Fairmont Brine
Products sludge, Pace Analytical Services is actually a NELAP certified lab with multiple offices across the
US (see https://www.pacelabs.com/about-us.html and https://www.pacelabs.com/environmentalservices.html ). The National Environmental Laboratory Accreditation Program is the preeminent
certification for any environmenta.1 testing laboratory, including those that analyze for radionuclides. But
bottom line, if Pace Analytical and ATS were analyzing the same sample of Fairmont Brine sludge and
Pace came up with 1,453.5 pCi/g Ra-226 and ATS came up 5.6 pCi/g Ra-226, I know whose numbers I
would believe.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
GP783

Curt;
I, along with Rodney Maze and Karen Hall from our Regional Field Office in Morehead for the Division of
Waste Management visited the Green Valley Landfill in. the Ashland area run by Republic Services last
week.
We reviewed manifests during our site visit and identified wastes being sent from Ohio with the paper
work signed by Cory Hoskins associated with Advanced TENORM Services. The analytical work
submitted with the waste shipments was also provided by Advanced TE NORM Services. I have attached
one of the submittals so you could see what is being submitted. I question the accuracy of the analyses
that I saw. If the analytical results were as low as they the paperwork presented, I do not understand the
need to ship the waste to Kentucky at a higher cost to the company.
I feel it is important to confirm that the waste was actually analyzed by a certified lab. When we met
with Cory he indicated he had equipment to measure the radioactivity, but he did not use it for analysis.
George Weems an inspector from the Frankfort Office and I plan to visit Blue Ridge Landfill on
Wednesday where the waste from WV (Fairmont Brine) was sent. We plan to meet with management
at the landfill and review manifests.
We would like very much if someone from you area, especially Chris Keffer could join us for the site visit
so we can screen for contamination while we are there. Also having Chris present to respond to
questions and concerns regarding radioactive materials would be very helpful.
Advanced TENORM Services is listed with the Division of Water as a Certified Lab for pH, TSS, and 0 &
G. They are on Interim Status since they are new. The lab is at their company address in the Morehead
Head County Public Library is the size of about two cubicles. There is no sink or water in the office and I
do not see how they could run a lab at the library. If they did they would be using the public restrooms
in the library to clean up their equipment, etc. from analyzing wastewater which would put the public at
risk. I have addressed my concerns with the DOW.
I am continuing to investigate our concerns regarding TENORM and seek to do all I can to protect the
personnel at the landfills and the communities they serve.
George
GP784
------
-m:
--------------
Sent:
To:
Subject:

Maze, Rodney (EEC)
RE: Analytical Results Submitted by Advanced TENORM Services
Rodney;
I will locate the correspondence that Curt forward to me regarding contact with Cory Hoskins in the next few minutes
and sent that to you.
Thank you!
George

Subject: Re: Analytical Results Submitted by Advanced TENORM Services
George,
Do you have the email from Curt where he advised Cory it was not acceptable to dispose of TENO RM waste from outside
~ state of KY.
~anks
Rodney
Rodney Maze
Hello Curt;
As we noted and mentioned on these analyses, LY's initials are shown on the "Sample Analyte
Count" As I recall from what Patrick Garrity from the Division of Water (DOW) shared with us in our
meeting in your offices, we can ask for the supporting documentation for the analytical results that were
submitted to Republic Services for the Green Valley Landfill facility. That would help us understand
where the results were obtained, the location of the lab or facility, and confirm their certification.
Please share your thoughts! I want to understand this situation better and identify all the individuals
involved. The initials are the same as the "Vice President" of Advanced TENORM Services.
I am concerned that we may not truly know what the characteristics are of the waste that have been
disposed of at Green Valley LF operated by Republic Services since the analytical results were provided
by Advance TENORM Services.
1
GP785

George
(ieorge P. PartridiJe Jr., Pfi:D, P.'E., Q.,'EP

Frankfort, KY 40601
(502) 564-6716 ext 4651-


Hello George,
Advanced TENO RM services does not have a license from our office to collect and analyze TENO RM
samples or any samples suspected of being contaminated with radioactive materials. I believe the
company has an office in Ohio so I will check with our colleagues there to see if the company has an
Ohio license. Ohio actually issues licenses to companies involved in the oil and gas industry. See the
attached copy of the amended license for Shale Testing Solutions of Lisbon, OH. Interesting both of
these companies reference the same EPA method 901.1: http://www.epa.gov/homeland-securityresearch/epa-method-901Fgamma-emitting-radionuclides-drinking-water Chris actually took photos of
the Thermo RllDEye System at the ATS office in West Liberty which appeared to be set up for a
laboratory type analysis with a heavy shield in place. That system may be adequate for testing for Ra226 and Ra-228 but I seriously doubt it. The RllDEye was designed for hand-held operation in the field
where quantification of radionuclides is not a primary concern but rather radionuclide identification. In
contrast to ATS, the laboratory employed by Waste Management to analyze this Fairmont Brine
Products sludge, Pace Analytical Services is actually a NELAP certified lab with multiple offices across the
US (see https://www.pacelabs.com/about-us.html and https://www.pacelabs.com/environmentalservices.html ). The National Environmental Laboratory Accreditation Program is the preeminent
certification for any environmental testing laboratory, including those that analyze for radionuclides. But
bottom line, if Pace Analytical and ATS were analyzing the same sample of Fairmont Brine sludge and
Pace came up with 1,453.5 pCi/g Ra-226 and ATS came up 5.6 pCi/g Ra-226, I know whose numbers I
would believe.
Regards,
2
GP786

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Vm,11.i;,l;ffA)
,-v~r:::~"~
f~Ol;\\TdOtt&_H~,LTH

Curt;
I, along with Rodney Maze and Karen Hall from our Regional Field Office in Morehead for the Division of
Waste Management visited the Green Valley Landfill in the Ashland area run by Republic Services last
week.
We reviewed manifests during our site visit and identified wastes being sent from Ohio with the paper
work signed by Cory Hoskins associated with Advanced TENO RM Services. The analytical work
submitted with the waste shipments was also provided by Advanced TENORM Services. I have attached
one of the submittals so you could see what is being submitted. I question the accuracy of the analyses
that I saw. If the analytical results were as low as they the paperwork presented, I do not understand the
I feel it is important to confirm that the waste was actually analyzed by a certified lab. When we met
with Cory he indicated he had equipment to measure the radioactivity, but he did not use it for analysis.
George Weems an inspector from the Frankfort Office and I plan to visit Blue Ridge Landfill on
Wednesday where the waste from WV (Fairmont Brine) was sent. We plan to meet with management
at the landfill and review manifests.
We would like very much if someone from you area, especially Chris Keffer could join us for the site visit
so we can screen for contamination while we are there. Also having Chris present to respond to
questions and concerns regarding radioactive materials would be very helpful.
Advanced TE NORM Services is listed with the Division of Water as a Certified Lab for pH, TSS, and 0 &
G. They are on Interim Status since they are new. The lab is at their company address in the Morehead
Head County Public Library is the size of about two cubicles. There is no sink or water in the office and I
do not see how they could run a lab at the library. If they did they would be using the public restrooms
in the library to clean up their equipment, etc. from analyzing wastewater which would put the public at
I am continuing to investigate our concerns regarding TENO RM and seek to do all I can to protect the
personnel at the landfills and the communities they serve.
3
GP787
George
<Adv TEN ORM Serv - Analysisfor Green Valley LF-Waste.pdf>
'
GP788
t/1m:
Maze, Rodney (EEC)

Re: Analytical Results Submitted by Advanced TENORM Services
image002Jpg
Sent:
To:
Subject:
Attachments:
Thanks
Rodney Maze
Rodney;
I will locate the correspondence that Curt forward to me regarding contact with Cory Hoskins in the next
few minutes and sent that to you.
Thank you!
George

Subject: Re: Analytical Results Submitted by Advanced TENORM Services
George,
Do you have the email from Curt where he advised Cory it was not acceptable to dispose of TENO RM
waste from outside the state of KY.
Thanks
Rodney
Rodney Maze
Hello Curt;
As we noted and mentioned on these analyses, LY's initials are shown on the "Sample
Analyte Count." As I recall from what Patrick Garrity from the Division of Water
(DOW) shared with us in our meeting in your offices, we can ask for the supporting
documentation for the analytical results that were submitted to Republic Services for
the Green Valley Landfill facility. That would help us understand where the results were
obtained, the location of the lab or facility, and confirm their certification.
1
GP789
Please share your thoughts! I want to understand this situation better and identify all
the individuals involved. The initials are the same as the "Vice President" of Advanced
TENORM Services.
I am concerned that we may not truly know what the characteristics are of the waste
that have been disposed of at Green Valley LF operated by Republic Services since the
analytical results were provided by Advance TENORM Services.
George
(jeorge P. Pahritfee Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
<imageOOl.gif>

'
Hello George,
Advanced TENO RM services does not have a license from our office to collect and
analyze TENO RM samples or any samples suspected of being contaminated with
radioactive materials. I believe the company has an office in Ohio so I will check with our
colleagues there to see if the company has an Ohio license. Ohio actually issues licenses
to companies involved in the oil and gas industry. See the attached copy of the
amended license for Shale Testing Solutions of Lisbon, OH. Interesting both of these
companies reference the same EPA method 90.1.1. http://www.epa.gov/homelandsecu rity-resea rch/ epa-method-9011-ga m ma-emitting-rad ion uclides-d rinking-water
Chris actually took photos of the Thermo RllDEye System at the ATS office in West
Liberty which appeared to be set up for a laboratory type analysis with a heavy shield in
place. That system may be adequate for testing for Ra-226 and Ra-228 but I seriously
doubt it. The RllDEye was designed for hand-held operation in the field where
quantification of radionuclides is not a primary concern but rather radionuclide
identification. In contrast to ATS, the laboratory employed by Waste Management to
analyze this Fairmont Brine Products sludge, Pace Analytical Services is actually a NELAP
certified lab with multiple offices across the US (see https://www.pacelabs.com/aboutus.html and https://www.pacelabs.com/environmental-services.html ). The National
Environmental Laboratory Accreditation Program is the preeminent certification for any
environmental testing laboratory, including those that analyze for radionuclides. But
bottom line, if Pace Analytical and ATS were analyzing the same sample of Fairmont
2
GP790
Brine sludge and Pace came up with 1,453.5 pCi/g Ra-226 and ATS came up 5.6 pCi/g Ra226, I know whose numbers I would believe.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of un_:vanted sources http://www.crcpd.org/StateServices/SCATR.aspx
N~

Curt;
I, along with Rodney Maze and Karen Hall from our Regional Field Office in Morehead
for the Division of Waste Management visited th12 Green Valley Landfill in the Ashland
area run by Republic Services last week.
We reviewed manifests during our site visit and identified wastes being sent from Ohio
with the paper work signed by Cory Hoskins associated with Advanced TENO RM
Services. The analytical work submitted with the waste shipments was also provided by
Advanced TENO RM Services. I have attached one of the submittals so you could see
what is being submitted. I question the accuracy of the analyses that I saw. If the
analytical results were as low as they the paperwork presented, I do not understand the
I feel it is important to confirm that the waste was actually analyzed by a certified
lab. When we met with Cory he indicated he had equipment to measure the
radioactivity, but he did not use it for analysis.
George Weems an inspector from the Frankfort Office and I plan to visit Blue Ridge
Landfill on Wednesday where the waste from WV (Fairmont Brine) was sent. We plan
to meet with management at the landfill and review manifests.
We would like very much if someone from you area, especially Chris Keffer could join us
for the site visit so we can screen for contamination while we are there. Also having
Chris present to respond to questions and concerns regarding radioactive materials
would be very helpful.
3
GP791
Advanced TENO RM Services is listed with the Division of Water as a Certified Lab for pH,
TSS, and 0 & G. They are on Interim Status since they are new. The lab is at their
company address in the Morehead Head County Public Library is the size of about two
cubicles. There is no sink or water in the office and I do not see how they could run a
lab at the library. If they did they would be using the public restrooms in the library to
clean up their equipment, etc. from analyzing wastewater which would put the public at
I am continuing to investigate our concerns regarding TENO RM and seek to do all I can
to protect the personnel at the landfills and the communities they serve.
I am available to participate in any meeting or visits as we need to. This is my highest
priority.
George
<Adv TENORM Serv - Analysis for Green Valley LF Waste.pdf>
'
GP792
-m:
Sent:
To:
Subject:
Attachments:

Maze, Rodney (EEC)
FW: TENORM in KY
KRS%20211.859%20Central%20Midwest%20Interstate%20Low-Level%20Radioactive%
20Waste%20Compact.pdf
FYI

To: Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH); Partridge, George (EEC)
Subject: FW: TENORM in KY
Hello gentlemen,
Looks like I had a telephone conversation with Mr. Cory Hawkins, Managing Member of Advanced TENO RM Services LLC
would encompass TENORM produced as a result of oil and gas exploration and production. Looking back on our
nversation, I wish I had also informed him in writing of the fact the compact forbid the disposal of out of compact
stes here in KY and if such waste were disposed, penalties could be assessed. But as they say, ignorance of the law in
excuse.
'

shall be the exclusive regulatory resporn~ibility of the states, except that no person

offense.
..,tucky Radiation Health Branch
East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
9"1s
GP793
Tel: 502-564-3700 ext. 4183

Fax:502-564-1492
Van:fJe~
r~t..IM..~ ..:!l
f'.A!:i!.lff!tJti.HlYU. ':rH

To: 'Cory Hoskins'
Hello Cory,
It was a pleasure speaking with you this morning regarding the disposal of TE NORM contaminated wastes from the oil
and natural gas industries. Until you called, I was not even aware that your company, Advanced TENORM Services, LLC
existed much less was headquartered in Ashland, KY. Looking at the KY Secretary of State's Office it appears you and
Solid Wastes and Hazardous Waste ever get around to drafting some TE NORM regulations for our cabinets and are
reaching out to the public and stakeholders for comment, we will most definitely be contacting you. Attached is a copy , .
of the KY Regulatory Statute dealing with the Central Midwest Interstate Low-Level Radioactive Waste Compact signed
between KY and IL. See http://www.lrc.ky.gov/statutes/statute.aspx?id=8498 or the CMC website at
(http://www.cmcompact.org/statutes/KRS%20211.862%20Definitions%20for%20KRS%20211.862%20to%20211.869.pdf
):
(8) "Naturally-occurring radioactive material" (NORM) means naturally occurring materials not regulated under
the Atomic Energy Act of 1954; as amended, whose radionuclide concentrations have been increased by or as a
Obviously this definition would encompass TENO RM produced as a result of oil and gas exploration and production.
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
GP794
Pay your fees on line at https:l/prd.chfs.ky.gov/rad epay/

e of. u.n.!la~~t.~.ed sources http://www.crcpd.org/StateServices/SCATR.aspx
tufitr~
~~Wft;Ufwy
fU\!'.l!fliTl0l'1,H~,LTH
GP795
elm:
Sent:
To:
Cc:
Subject:
Attachments:

Weems, George (EEC); Maze, Rodney (EEC); Keffer, Christopher (CHFS Rad Hlth);
Anderson, Danny J (EEC); Briggs, Lindsey (EEC)
RE: Confirmation of FBP - Waste Shipments
Fairmont Brine Processing - Waste Sent to Blue Ridge Landfill.pdf; Quaterly Waste
Reports for Blue Ridge Landfill - 2015.pdf
Curt;
On the site visit to Blue Ridge Landfill, 2700 Winchester Rd, Irvine , KY (Al 998) that was conducted by Chris Keffer,
George Weems (DWM), and myself, we confirmed that Fairmont Brine, located at 168 AFR Drive, Fairmont, WV, Contact
Cory Hoskins, has conducted 47 waste shipments to Blue Ridge Landfill between the dates of August 18th and November
16th 2015.
The Profile #/Contract is Y4002150 according to the Advanced Disposal records provided to us.
The focus of this site visit was to confirm that Blue Ridge Landfill had received waste from Fairmont Brine located in
WV. In the process of searching for manifests from Fairmont Brine, we also located waste manifests showing TENO RM
s received from "Cambrian Well Services" located in Norwich, OH and "Nuverra" also located in Norwich Ohio. A
rch of the manifest to identify all TENO RM received by the facility was not conducted at this time, but will be
eduled in the future. It is important to assess the total waste inventory of TENO RM disposed of at Blue Ridge
Landfill.
I have attached the printed information, that Mr. Billy Bowles, Site Manager/Special Waste provided me. I will be
requesting the waste manifest for all shipments by Fairmont Brine, as well as conducting a thorough search for all
TENO RM waste that has been disposed of at Blue Ridge.
Please note on the attached documents that the contact person for the generator company Fairmont Brine, Cambrian
Well Services, and Nuverra is Cory Hoskins. Mr. Hoskins is also signing off as the generator.
The billing name and address on the forms is:
BES LLC.
32 Crestview Drive
West Liberty, KY 41472
Contact: Cory Hoskins
As we seek to identify landfills in Kentucky that have received TE NORM waste I am searching our TEMP0360 files and
retrieving the "Quarterly Waste Quantity Reports" for our landfills. Please find attached the "Waste Received Quarterly
Reports" provided by Advance Disposal Services for the Blue Ridge Landfill for 2015. Please note the following:
,,,, .
Muskingam, OH only shipped 1.24 tons to Blue Ridge and it was used as "Alternate Daily Cover" reported in the
July-August-September Quarter.
Marion County is mentioned but not associated with Ohio. This would indicate the Marion referenced is in
Kentucky.
GP796
What this mean is that Advanced Disposal has received 47 shipments of waste from FBP in Norwich, Ohio and it is not
reported on their quarterly waste reports.
It also appears that the TENORM waste being received by this landfill/Advance Disposal from other companies is also
not being reported as well on their quarterly reports.
What has been reported has been used as "Alternate Daily Cover" which make the inhalation pathway and transport off
site due to vectors (contaminated individuals, equipment, etc.) and wind blow dust a significant exposure pathway
concern, particularly since there is a public school across from the landfill and the entrance where the trucks enter and
l~ay~ th~fci~ility.Jh.e ~~posre qrnld potentially result in exc~ss cancer risk ~hat would manifestitself in fljture_y~~rs in
the health of the receptors, both on and off site for those that have been exposed to the radioactive constituents in the
waste.
It appears that the Marion County reported for Kentucky is actually Marion County Ohio, which means that 818.89
tons of waste from Fairmont Brine Processing was applied as "Alternate Daily Cover" at the landfill which makes
operator exposure and off-site transport to sensitive receptors by the inhalation pathway a grave concern from the dust
and transport vectors. This thought seems reasonable since no municipal waste was reported from Marion County and
that the waste received for the last two quarters of 2015 corresponds to the period that Fairmont Brine shipped waste
to Kentucky.
I am working to identify all the company names that Cory Hoskins is using and how he is identifies the waste he is having
shipped from Kentucky from out of state and identifying additional .companies that may be shipping waste containing
TENO RM as well.
Thank you again for all you and your Branch is doing to take the initiative on this investigation into TENO RM that is
destined for our landfill.
George
(jeorge P. PartrU{ge Jr., Pfi1J, P.'E., Q.,'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
'
(My understanding is that Fairmont, WV is located in Marion County, West Virginia and Norwich, OH is located in
Muskingum County, Ohio.)
GP797
Fairmont
Cil';i iti We$1 Vifg<ni<i
f alrmonlis a tlti tr! Mario.n Cl)l.mty, We.s,t Vl{gioia, Uniied Stales The
population v;as 18, 704 at the 2010 census, It is 1t1'e ~oofl'ti/ seal of Marron
County. VV!kipedia
GP798
-om:
Weems, George (EEC)

RE: RE: Confirmation of FBP - Waste Shipments
Sent:
To:
Subject:
George, how was this disposal activity discovered?

Cc: Weems, George (EEC); Maze, Rodney (EEC); Keffer, Christopher (CHFS Rad Hlth); Anderson, Danny J (EEC); Briggs,
Lindsey (EEC)
Subject: RE: Confirmation of FBP - Waste Shipments

Curt;
On the site visit to Blue Ridge Landfill, 2700 Winchester Rd, Irvine, KY {Al 998) that was conducted by Chris Keffer,
16th 2015.
" - - - Profile #/Contract is Y4002150 according to the Advanced Disposal records provided to us.
was received from "Cambrian Well Services" located in Norwich, OH and "Nuverra" also located in Norwich Ohio. A
search of the manifest to identify all TENO RM received by the facility was not conducted at this time, but will be
scheduled in the future. It is important to assess the total waste inventory of TENO RM disposed of at Blue Ridge
Landfill.
BES LLC.
32 Crestview Drive
..-.~e seek to identify landfills in Kentucky that have received TENO RM waste I am searching our TEMP0360 files and
, ~eving the "Quarterly Waste Quantity Reports" for our landfills. Please find attached the "Waste Received Quarterly
GP799
Muskingam, OH only shipped 1.24 tons to Blue Ridge and it was used as "Alternate Daily Cover'' reported in the
Kentucky.
reported on their quarterly waste reports.
It also appears that the TENO RM waste being received by this landfill/Advance Disposal from other companies is also
not beingr~pe>,rtecl as '1\(ell c>n t~eir quarterly reports.
leave the facility. The exposure could potentially result in excess cancer risk that would manifest itself in future years in
waste.
tons of waste from Fairmont Brine Processing was applied as'"Alternate Daily Cover" at the landfill which makes
to Kentucky.
I am working to identify all the company names that Cory Hoskins is using and how he is identifies the waste he is havinA
shipped from Kentucky from out of state and identifying additional companies that may be shipping waste containing
TENO RM as well.
Thank you again for all you and your Branch is doing to take the initiative on this investigation into TENO RM that is
destined for our landfill.
George
(jeorge P. PartridiJe Jr., Pfi1J, P.'E., Q..'.EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP800
Fairmont
f airmorit is a dty ID Marion Co1..mty, West Virgl!')i<i~ Urflled States The
at the 2010 cenSU$. il is 1he eoorrti1 seal of Marion
Cijunly. Wlkipedta
popu!~lf,[)n was 18, 704
.li.
..
/)''?!'
t p\'11.!:
@ID
M!llP ~+.,: (1it) 1.6 Google
GP801
e!~=
To:
Subject:
Weems, George (EEC)

Billy Bowles
More Manifests
Hi Billy,
George Partridge wants the manifests of all of 2015 and to current on 2016. When do you think you could get them to
me for him? PDF'ing and emailing them would be fine. You have to keep the attachments under 8 meg per email
though. Thanks, George
GP802
. .m:
Sent:
To:
Cc:
Subject:
Attachments:

Chlebowy, William; Cecil, Kim (KCecil@republicservices.com)
Bhattacharyya, Anjan; Frame, Jason R (Jason.R.Frame@wv.gov); Keffer, Christopher
(CHFS Rad Hlth); Partridge, George (EEC)
FW: 4127 Green Valley No 80 CAMC_2016-02-05
4127 Green Valley No 80 CAMC_2016-02-0S.pdf; 910383-1214 Bulk Download.zip
Hello Bill,
Yes I would have to agree, the attached spectra most definitely looks like the radiation portal alarm on the load of
wastes from the Charleston WV Area Medical Center was due to Tc-99m on Peak Easy analysis. And with a 6 hour halflife, I would have to presume the waste is fairly fresh. If memory serves me correct, this is the second time a medical
facility in WV has sent radioactive wastes to Green Valley Landfill in Ashland, KY. Obviously, these NRC licensed medical
facilities are not doing a good job of segregating and surveying their medical waste prior to disposing of this material in
the regular trash. I am including Jason Frame with the WV Radiological Health Program and our Regional Agreement
State Officer, Ms. Monica Ford on this e-mail in hopes that they might follow-up on this. I have talked to our fellow
members of the Central Midwest Interstate Low-Level Waste Compact in IL and they evidently have the same problem in
their state with the occasional out-of-state medical waste shipment setting off a radiation portal monitor at a landfill in
IL. Our IL colleagues agreed that at long as we determine that the alarm is due to short-lived medical isotopes, then
sposal of out-of-compact wastes is not an issue .
osal of long-lived TENO RM wastes from the oil and gas industry on the other hand is another matter entirely. Oil
an gas exploration and production fluids from hydraulic fracturing operations in non-compact states such as OH, PA,
WV and elsewhere should not be accepted for disposal in KY under any circumstances. Our KY Revised Statutes strictly
prohibit such activities and the penalties for doing so are significant.
1
GP803
KRS 211.863 Control of commerce of low-level radioactive waste in and out of Kentucky
(3) Naturally-occurring radioactive material (NORM) as defin~dinl(RS211.86:2(8)

shall be the. exclusive regulatory responsibility. of the. states, ~~c~pt,th.at'ii'ii.I1~rs.Qn:
s.n~1f~P:0~,
l~~~P:'P:~Ir ~~~~Bx~:mK~~rt<l;l .(~9R.Hr9~~-~t~~ci~;f~~ ....
..s. ifi.~ehg1 . ,.01rd~~~qs~.of.~~ch 1II1p~rteQ in~tefi~P~J<el'itl1ckY,

if:ih~ iri_ipgr{s~2r;p!si>.9's~i ~i~ fnQQ~~~~ehr~11:11jiQiict{~6[ the ~olliijii~s.i~~- .
t~gi91ffor qf
KRS ~ll.862 Definitions forKRS 211.861 to :211.869. http://www.lrc.ky.gov/statut.es/statute.aspx'?id=8S01

radioactivity of r9cks ?r s.oils,pr ~ackground radiation, but instead ioa-tir~td
~~1~~~~f~rN~~~~~i~f~&~~W;is.~eE'.~~~1~g1c~1frJnliet,~2~~y . cQritro1rao1~J?r~ctt~es
KRS 211.869 Penalties. http://www.Irc.ky.gov/statutes/statute.aspx?id=8505
ten thousand dollars ($10,000) nor more than one hundred thousand dol.lars
offense.
Please let me know if you have any questions or comments concerning this matter.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Zlenm~~
1.~,~~
From: Chlebowy, William [mailto:WChlebowy@republicservices.com]

GP804
Cc: Cecil, Kim
Subject: 4127 Green Valley No 80 CAMC_2016-02-05
-iCurt:
Just following up on some paperwork. We had a roll off box from Charleston Area Medical Center set
off the alarm last Friday, Feb 5. We set the box over to the side, scanned it with the detector, then ran
the box back over the scale about an hour later. The alarm did not go off and we disposed the load. The
Identifier identified the isotope as TC-99m, an isotope that has been identified in the past, with a
confidence level of 10. The data and scan are attached.
Same issue - an out-of-state load from a state not in the Compact sets off the detector.
Thanks.
ttR~
~~
REPUBLIC
SERVICES
We'll handle it from here:

William l. (Bill) Chlebowy, P.E.
Environmental Manager
2157 Highway 151

Frankfort, KY 40601
e WChlebowy@republicservices.com
0 502-209-3816 c 502-403-8908
w republicservices.com
GP805
.om:
Sent:
To:
Subject:
Delong, Deborah (EEC)

FW: More Manifests
See 6efow. 'We wi[[ see wliat comes of tliis. I
wi[[ /(g.ep you postecf.

To: Billy Bowles
Subject: More Manifests

Hi Billy,
GP806
Cc:
Subject:

Ryan Hall; Chance Richie
McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge,
George (EEC); Fowler, Kathy L (CHFS PH); Frame, Jason R (Jason.R.Frame@wv.gov)
RE: Water recycling and TENORM disposal
Hello Mr. Hall,

Yes, our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompact.org/) of which KY is a member
with IL, strictly prohibits the disposal of out-of-compact wastes in the Commonwealth of Kentucky. That includes EPA
defined "special wastes" containing technologically enhanced naturally occurring radioactive materials generated from
the oil and gas exploration and production fluids and brines from out-of-compact operations. This office interprets "the
region" in KRS 211.863 to mean strictly the Commonwealth of Kentucky and the State of Illinois. No out-of-compact
generated TENO RM contaminated wastes from WV, OH, PA or any other state should be disposed of here in KY. That
would include the disposal of sf udge generated at your facility in KY from the processing of produced water from WV oil
and gas wells. That TENO RM contaminated wastes material should not be disposed of in landfills in the Commonwealth
of Kentucky. As for injecting that out-of-state oil and gas production fluid containing TENO RM in the company's disposal
wells here in KY, I am going to have to defer to my colleagues in the solid and hazardous waste divisions of the Energy
and Environment Cabinet whom I am including on this e-mail. But having said all of that, I would love to see your
.mpany's "radiation health plans and laboratory data".
s.hall .be the exclu,sive re?ul~toryresponsibility of the .~tate~, .~xcep{{llat[8 ]J~tipp
~rlf~~i!1~~~~~~r~:~}.t!~i~~~~~\ty,
KRS 211.862 Definitions for KRS 211.861to211.869. http://www.Irc.ky.gov/statutes/statute.aspx?id=8501

radioac~ivity ~f ro:ks or s.?il~, or ~ackgr?tmdradiation, ~ut .instead. f~{6f~'lg
~~~~~f~~~~M~~~~!~~~i~g!~Jis;i$~1!~~19gi~Afi;~11fi~h"s~t@y.9ontroJi~W(pr~~!Jceg
KRS 211.869 Penalties. http://www.lrc.ky.gov/statutes/statute.aspx?id=8505

offense.
GP807
One other comment. You said that Shalewater operates a business here in the Commonwealth of Kentucky. However, I
could find no registration of the company on the KY Secretary of State's website (https://app.sos.ky.gov/ftsearch/ ). I
believe all companies doing business in the Commonwealth of KY are required by law to register with the Secretary of
State's office and obtain the required permits necessary to operate (http://onestop.ky.gov/operate/Pages/permits.aspx ~
).
A...
If you have any additional questions or comments concerning this matter, please do not hesitate to contact me.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Vaw.m~
~f.,,.-.,.~
fi!'!/
r~~1..1rn6,t~!A1-1v.L111
From: Ryan Hall [mailto:rhall@shalewater.com]

Subject: Water recycling and TENORM disposal
Hello Curt,
We had been approached by a landfill operator and they gave us a competitive bid for disposal. We were then
notified that 211.863 prohibits disposal of NORM from outside of the "region". I am reaching out to you today
because we have existing operations near Kentucky, and may be siting future locations within your boarders.
I have several questions as it relates to that. Do you interpret "region" to be different than "state"? Along those
same lines, if I am operating a disposal well in eastern Kentucky it is very ptob(lble that I am receiving some
produced water from WV wells. I generally put all of my water through a pretreatment step. Pretreatment
generates a sludge that will have some TENORM signature and part of this will have been from out of state
sources. Would this rule also prohibit me from accepting out of state produced water for underground injection
in KY?
We would be more than happy to share our radiation health plans and laboratory data with you.
Best,
Ryan Hall
Technical Director
2
GP808
Shalewater Solutions, LLC
rhall@shalewater.com
-bile:(724) 289-7475
Office: 855-303-9416
37 Grande Meadows Dr. Ste. 201
Bridgeport, WV 26330
HILLSTONE
ENVIRONMENTAL
..
GP809
. .m:
Sent:
To:
Subject:
Attachments:
Maze, Rodney (EEC)

Maybriar, Jon (EEC); Partridge, George (EEC)
Fwd: 4127 Green Valley No 80 CAMC_2016-02-05
image004jpg; ATTOOOOl.htm; image005jpg; ATT00002.htm; ATT00003.htm;
imageOOl.png; ATT00004.htm; ATT00005.htm; 4127 Green Valley No 80 CAMC_
2016-02-05.pdf; ATT00006.htm; 910383-1214 Bulk Download.zip; ATT00007.htm
Rodney Maze
From: "Chlebowy, William" <WChlebowy@republicservices.com>
Date: February 12, 2016 at 9:47:03 AM EST

To: "'rodney.maze@ky.gov'" <rodney.maze@ky.gov>
Subject: FW: 4127 Green Valley No 80 CAMC_2016-02-0S
Hi Rodney:
Want to share this e-mail with you. This is the procedure we set up with the KY
Radiation Health Branch when a load sets off the radiation alarm. The KY Radiation
Health Branch doesn't have the resources to respond to each alarm and they have allowed
us to troubleshoot and send data to them.
For this particular case, we scanned the load that set off the alarm on Friday, Feb 5, with
the FLIR Identifier and identified the isotope as TC-99m with a confidence level 10.
We've had Tc-99m hits in the past and since the radiation dissipated quickly so as the
alarm did not go off after the load re- crossed the scale, we landfilled the load. We also
forwarded the data to the KY Radiation Health Branch for concurrence.
We've had cases where the radiation does not dissipate quickly to where the alarm keeps
going off after re-scaling. In those cases, we forward the data to the KY Radiation Health
Branch and they will advise us if the load is acceptable to landfill. The box will sit until a
determination is made.
Thanks.
William L. (Bill) Chlebowy, P.E.
Heartland Area
2157 Highway 151
1
GP810
-om:
Sent:
To:
Subject:
Weems, George (EEC)

FW: TENORM - technically enhanced naturally occurring radioactive material
George, did you perchance download Cory's Website? If not, this may be the only evidence you have on their
misleading web presence. I just tried to do so and he has pulled it "for maintenance".
About Our Company

Cory Hoskins - President
Cory holds a physics degree and mathematics minor and has 15 years of experience in environmental
compliance, including complex radiological issues in various states. He is also the president of bes
environmental services, a company providing environmental remediation, transportation, disposal, laboratory
and consulting services to general industry, municipalities, and military and government entities.
~tp:Uadvtenorm.com/about/
GP811
-m:
Sent:
To:
Cc:
Subject:
Cleveland, Daniel (EEC)

Johnson, Kari; Gaddis, Sarah (EEC)
Higginbotham, Jeri (EEC); Partridge, George (EEC)
FW: Water recycling and TENORM disposal
Kari,
As discussed, below is an email chain from the company wanting to utilize injec!ion wells in Kentucky to dispose of
produced water/production fluids that have been, for lack of a better word, separated from technologically enhanced
naturally occurring radioactive materials (TENORM). Also in this chain is the email from Radiation Health Branch
advising this company it is illegal to transport NORM/TENORM into Kentucky from any state except Illinois and referring
the injection well question to HWB and SWB.
My understanding is that EPA has primacy over injection wells, but I don't know who that contact may be. Also, I know
DOW regulates production fluids/brine, so I think this may be a CTAB question as well.
Curt Pendergrass at CHFS may be able to answer any questions about the proposed disposal and the effects ofTENORM
on the water. George Partridge in SWB has been working with him regarding TENO RM sludges as well.
. .nks
Daniel Cleveland, Attorney

Energy and Environment Cabinet
Office of General Counsel
2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
Daniel.Cleveland@ky.gov
Confidentiality Notice: This communication contains information which is confidential, attorney work product and
covered by the attorney-client privilege. It is for the exclusive use of the intended recipient(s). Please note that any form of
distribution, copying, forwarding or use of this communication or the information therein is strictly prohibited and may be
unlawful. If you have received this communication in error please return it to the sender and then delete the
communication and destroy any copies.

To: Cleveland, Daniel (EEC)
Subject: RE: Water recycling and TENORM disposal
Mr. Hall is asking if his company can inject "out-of-state oil and gas production fluid containing TENORM in the
company's disposal wells here in KY." Curt, in Public Health, is deferring to his colleagues in the solid and hazardous
waste divisions of the Energy and Environment Cabinet. It sounds like a question for you or Kevin. Also, Curt couldn't
.~,"~i~~-~"=~any registered on the SOS website.


1
GP812
To: Ryan Hall; Chance Richie

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC); Fowler, Kathy L
(CHFS PH); Frame, Jason R (Jason.R.Frame@wv.gov)
Hello Mr. Hall,
Yes, our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompact.org/) of which KY is a member
-- -- -fhe oil andgasexploration and prodactiunfluids and brines from out-of~compact operations;-This office interprets~he
generated TENORM contaminated wastes from WV, OH, PA or any other state should be disposed of here in KY. That
would include the disposal of sludge generated at your facility in KY from the processing of produced water from WV oil
of Kentucky. As for injecting that out-of-state oil and gas production fluid containing TENORM in the company's disposal
company's "radiation health plans and laboratory data".
Prohibitions -- Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id=8502
shall be the exclusive regulatory responsibility of the states, ~~~~p{ili~fu.d~p,ets~~
&?fJi{~i;~~~~rt''l~~;~(fii~!Bti~l~x.'
KRS 211.862 Definitions for KRS 211.861to211.869. http://www.lrc.ky.gov/statutes/statute.aspx?id=8501

ra_dioactivity.f r()~ks .or sa,ils, o~ba~kground ~ad,ia.ti_~f1'. bl1t ~nstead fefets;{tj
~t~~~~i~~:f c:~. ;~~~~~~~}t~~t1t~~a4;~12:i~q~\i~]~hlJ~p15~atiy_~9~trf!naw~pra~it~~

(1) Any person who fails to comply with any provision ofKRS 211.859 or 211.863, or
offense.
State's office and obtain the required permits necessary to operate (http://onestop.ky.gov/operate/Pages/perrriits.asp.
).
2
GP813
Regards,
~t Pendergrass PhD
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
/(f/JJIJ~~
."
r-:Aovrrir>t~~MiJ.)ti'n1

. l o Curt,
.We had been approached by a landfill operator and they gave us a competitive bid for disposal. We were then
Best,
Ryan Hall
Technical Director
le:(724) 289-7475
Office: 855-303-9416
3
GP814

16\ HILLSTONE
ENVIRONMENTAL
GP815
-m:
Sent:
To:
Cc:
Subject:
Ryan Hall <rhall@shalewater.com>

Pendergrass, Curt (CHFSDPH)
Chance Richie; McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth);
Partridge, George (EEC); Fowler, Kathy L (CHFS PH); Jason R Frame
Re: Water recycling and TENORM disposal
Hello Curt,
Thank you for the prompt and informative response. To be clear, I stated in the original email that we have
existing locations near Kentucky and may at some point in the future wish to locate within the state. We do not
have anything there at the present (nor have had anything in the past). The line of questioning was related to
future opportunities. I will follow up with the Energy and Environment Cabinet concerning the disposal well
question.
Thanks again,
Ryan Hall
Technical Director
,lewak" Solutions, LLC

Mobile:(724) 289-7475
Office: 855-303-9416
On Feb 12, 2016, at 10:20 AM, Pendergrass, Curt (CHFS DPH) <Curt.Pendergrass@ky.gov>
wrote:
Hello Mr. Hall,
Yes, our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompact.org/ ) of which
KY is a member with IL, strictly prohibits the disposal of out-of-compact wastes in the Commonwealth of
Kentucky. That includes EPA defined "special wastes" containing technologically enhanced naturally
occurring radioactive materials generated from the oil and gas exploration and production fluids and
brines from out-of-compact operations. This office interprets "the region" in KRS 211.863 to mean
1
GP816
strictly the Commonwealth of Kentucky and the State of Illinois. No out-of-compact generated TENO RM
contaminated wastes from WV, OH, PA or any other state should be disposed of here in KY. That would
include the disposal of sludge generated at your facility in KY from the processing of produced water
from WV oil and gas wells. That TENO RM contaminated wastes material should not be disposed of in
landfills in the Commonwealth of Kentucky. As for injecting that out-of-state oil and gas production fluid
containing TENO RM in the company's disposal wells here in KY, I am going to have to defer to my
colleagues in the solid and hazardous waste divisions of the Energy and Environment Cabinet whom I am
including on this e-mail. But having said all of that, I would love to see your company's "radiation health
plans and laboratory data".
-
--
(3) Naturally-occurring radioactive material (NORM) as
definedi~KR.S211.86.2(8)
~!11.11 ~e,. t~~. ~J,Cg}~::~i".~:E~~~1at?rx.~~~pc.>n.sibi!it~.c.>f.!~~.~t~t~~ 1 .~~f~Pi'!h~f~~~~r~o~
fl!i1filfiliftlit~ii$~1~!!1FT~;
KRS 211.862 Definitions for KRS 211.861 to
211.869. http://www.lrc.ky.gov/statutes/statute.aspx?id=8501
practices. Naturally occurring radioactive material does not include t?e ~at.ural
radi~a~ti~it~ .of yocks . or soil~, or back~o1md r~~i~tion~. b.ut instead f~fers.to'
~~W~~ll~~~~~~~}[~~~y~~1~;!~~un21Qgis~1r)r~!1~~2d~y-q~n~911~b1~:1J1~61ic~s:
offense.
One other comment. You said that Shalewater operates a business here in the Commonwealth of
Kentucky. However, I could find no registration of the company on the KY Secretary of State's website
(https://app.sos.ky.gov/ftsearch/ ). I believe all companies doing business in the Commonwealth of KY
are required by law to register with the Secretary of State's office and obtain the required permits
necessary to operate (http://onestop.ky.gov/operate/Pages/permits.aspx ).
If you have any additional questions or comments concerning this matter, please do not hesitate to
contact me.
Regards,
Mailstop HSlC-A
GP817
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<image001.jpg>

Hello Curt,
We had been approached by a landfill operator and they gave us a competitive bid for
disposal. We were then notified that 211.863 prohibits disposal of NORM from outside of the
"region". I am reaching out to you today because we have existing operations near Kentucky,
and may be siting future locations within your boarders.
I have several questions as it relates to that. Do you interpret "region" to be different than
"state"? Along those same lines, if I am operating a disposal well in eastern Kentucky it is very
probable that I am receiving some produced water from WV wells. I generally put all of my
water through a pretreatment step. Pretreatment generates a sludge that will have some
TENORM signature and part of this will have been from out of state sources. Would this rule
also prohibit me from accepting out of state produced water for underground injection in KY?
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
GP818
-m:
Sent:
To:
Cc:
Subject:

Hello George,
Since you first brought it up, at our meeting, I have been thinking about it and I could not agree more. The EPA
classification of oil and gas exploration and production fluids and brines as "special wastes" does not apply to the
companies that are in the waste processing business. These companies take "special wastes" as feedstock and generate
potentially hazardous waste on the backend separating and concentrating those constituents. And as you said, this
includes not only TE NORM but potentially heavy metals and organics. What we really need is a legal opinion from US
EPA on the matter. If EPA says the special waste provision applies only to producers and companies handling those
produced fluids without modification or further processing, then I think we have all the ammunition we need to go after
Advanced TENORM Solutions, Fairmont Brine Processing, Shalewater Solutions and others.
In the meantime, I have asked my superiors to contact our Office of Legal Services to get their opinion on the matter.
And yes I agree, Chris is great person to work with and have working for you. No one puts forth more effort and does so
without ever complaining, even if means trudging around a landfill in the cold and snow.
t/fve a nice weekend.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky .gov /dph/radioactive .htm
v"'-'*tu~
l~f~i\nl~4nt,!l
f~Ati!ATlON~HIDtt:n-1

e l u r t I
1
GP819
chemicals that are present. As a result they are creating a new level of "TENO RM" waste that has not been addressed tam.
date. We need to investigate all the chemical constituents, those that are radioactive as well as those that are not. I ~
that are so much more hazardous than the initial waste stream produced from the fracking operation.
th~ cell where !he \/Va~!e from FBP was pl~ced. It was very cold and windy vvi~h snow blowing and even moisture in.c>Ur
beards freezing. No one could have worked harder or done a more thorough job than Chris did. Also the positive spirit
and the way he approaches his work, you would have thought we were working under ideal conditions in nice
I am so grateful and appreciative for all you and your Branch/Division is doing to address the issue of radioactive waste
George
<george P. Partridff e Jr., Pfi'D, P.P., QPP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Patrick.
Patrick J. Garrity
Frankfort, KY 40601
Phone: {502)564-3410
Fax: {502) 564-2741
GP820
...J1L1t: Tuesday, February 09, 2016 12:24 PM
~Garrity, Patrick (EEC); Stewart, Kevin (EEC)

Hello gentlemen,
(http://www.fairmontbrineprocessing.com/ ). George's comment regarding the fact that Fairmonris not actually in the
Regards,
Mailstop HS1C-A
kfort, KY 40621
502-564-3700 ext. 4183
Fax: 502-564-1492
7/nnfufiff~,
I~~~~~
w.O:JATitl1'4A:\H:i>'A:n1

Brine
attatchment
GP821

Office: (304)356-4303
Fax: (304) 558-0524
From: Partridge, George (EEC) [mailto:Georqe.Partridge@ky.gov]

To: Frame, Jason R
Jason;
TENORM disposal.

4
GP822
-k
forward to hearing from you!
George


Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
Hello Mr. Frame,
-
Pendergrass PhD
5
GP823
H-
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky.gov/dph/radioactive .htm
l)j_s_pgs~ ()tt1nw9ri!ed sources http://www.crcpd.org/StateServices/SCATR'.aspx
/(tZllJ&~--
- -- - - - - - - - - - - - --- ------- --- - _. - - -
f!Jlltf!ft.'rltH~ A}tiSAi.TH

Mr. Pendergrass,

Office: (304)356-4303
Fax: (304) 558-0524

To: Frame, Jason R
GP824
Hello Mr. Frame,

ile KY does not currently have any regulations dealing with the control and disposal of NORM/TENORM waste
erated in the oil and gas industry from hydraulic fracturing, we do have statutes on the books establishing the Central
is required.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
.nded recipient, be advised that you have received this e-mail in error and
any use, dissemination, forwarding, printing, or copying of this e-mail is
.rohibited. If you have received this e-mail in error, please notify the sender
herein.

Dr. Pendergrass,
in place and that each landfill may have their own limits on what they except or turn away in regards to radiation levels,
n.r.frame@wv.gov ).
7
GP825

Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
send$r by reply e-mail and destroy all copies of the original message.
GP826
f/lm:
Sent:
To:
Cc:
Subject:
Attachments:

KRS 224.46-530_statute.pdf
Hello George,
I could not agree more with everything you say about Dr. Ling, Mr. Hoskins and their activities. This most definitely
should not go unpunished. One comment I would make though regarding EEC's authority. My reading of the statute
KRS 224.46-530 would indicate that if we can prove the processed waste being disposed of by ATS generated by
Fairmont Brine and Shalewater Solutions and others no longer meets the EPA definition of "special wastes" but is
rather hazardous wastes after processing, I think EEC has all the authority it needs to pursue actions.
(k) To regulate hazardous waste that is radioactive except to the extent that
such waste is source, special nuclear or by-product material as defined by
the Atomic Energy Act of 1954, as amended, (68 Stat. 923);
, t having said that, I am confident that our cabinet will pursue this matter to the fullest extent of the law.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
r~
~~~~
r~\!!!JtffJON.l-lt::t1J;'_iH
Sent:
9>ject:
GP827
Curt;
~
Cory Hoskins has two businesses incorporated out of his home, BES LLC and Advanced TENO RM Services. He appears ~
attractive cost solution to their TE NORM disposal needs. He is using the BES LLC company name and signing off as
things for him: 1) TE NORM is not mentioned in the correspondence or the name of the company that the landfill or
waste that was gener-ated in~state~and not regulated, so they feel comfortable a~ceptirig it,
I have never seen such misrepresentation in the environmental field in my career by individuals that know the
Dr. Ling also should know the safety precautions one would should take when handling or sampling this type of
waste.
violated. Most of all his actions are jeopardizing the future well-being of those that are exposed to this waste,
disposed of at their facilities:
I want to do all I can
to support the work that you and your Section
A...
"lit
is doing to safely manage and regulate TE NORM.
Thanks again for including me in the meeting and for all that Chris has done to help educated us about TENORM and
Geroge
<george P. Partridge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP828
. . . .om: Pendergrass, Curt (CHFS DPH)

~ent: Tuesday, February 09, 2016 8:13 AM
Thanks George for sharing the correspondence with Dr. Ling with us. It will be interesting t.o hear what Dr. Ling has to
say about the Central Midwest Compact and its ban on the disposal of out-of-compact TE NORM wastes in KY. But
Regards,
Curt

flj,;~~~;~;~~~~~:;e~:~~~i;:~;o~~~~~i~~f1:)s~!t~:~::c~!~:J~n~~~~~(S)
S\l(lll iillp6rt'ila!uta1lyg~ggrriltg radj8aqtfy)naterial (N~SM) . .froin Ol1tsidy. th~
region.for Cli:SoP~sal i~'~eurucky, (iJ"Hispp:seofsu{;h impor1~<lp'1teria1 !11.Kentucky,
if the frrip9~s or i:lisposa:(ar~jii,:c;6niste1It'\V!th 'polices .of the tofutnis.s!on.

offense.

radioactivity of rocks or soils, or background radiation, but instead refers tq
...
mateti~s''1hos~.Jad!6ad(v~tYrn.',t~~hn.oi6g'iC(lHyenh~cecl.bycontro1lablepfactices
~ b)rp. asfhl1inan.prac#9es);
...
..
GP829

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http_;//www.chfs.ky.gov/dph/radioactive.htm
Vn:u~,~
~IJI:!':::.~
~J\tll;t\Tli:.lJ't&HP.L'iH


Cc: Cory Hoskins; Robert Brenna; Richard Yuen
Hi George,
.... I am currently on vacation, back Thursday. Cory Hoskins is KLVTEC business partner on TENORM issues as it relates
to hydraulic fracturing produced wastes, and he or my other KLVTEC colleagues can assist you as needed during my
absence.
Leong
Dr. Leong Ying
KL YTEC - President
leonq.yinq@klvtec.com
Mobile: 212 203 5842
GP830

~~: klystar@hotmail.com
~bject: New Comment from KLYSTAR.com
Hi Leon,
First
name:
Last
name:
George
Partridge
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
Comment:
Kind Regards
George Partridge

Checked by AVG-www.avg.com
GP831
Cc:
Subject:
Attachments:

Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Keffer, Christopher (CHFS Rad Hlth);
RE: WW Application and QAP for Advanced TENORM Services
KY08061 WW Application 2015.pdf; KY08061 WW QAP.PDF; Advanced TENORM
Services - Photos - 020416.pdf; Adv TENORM Serv - Analysis for Green Valley LF
Waste.pdf
Thanks George. I didn't see anything in their Wastewater Laboratory application regarding the analysis for radionuclides
at their rented office in the Morgan County Public Library. Obviously, based on the presence of radioanalytical
equipment at this office in West Liberty that both you and Chris took pictures of, this rented space is being used for
activities not covered by the DOW permit. And yes, where do they clean their TENO RM contaminated lab equipment
and dispose of their TENO RM contaminated lab wastes?
.ilstop HSlC-A
.kfort, KY 40621
. e l : 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of un1"anted sources http://www.crcpd.org/StateServices/SCATR.aspx
v."m
IW.t.f'tl,MATlOH

Cc: Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Keffer, Christopher (CHFS Rad Hlth)
Subject: FW: WW Application and QAP for Advanced TENORM Services
Curt;
Morgan County Public Library where there appears to be no sink or running water, only an partitioned office area
~the door labeled "B" on the front, no company name. I do not see how he could be running a laboratory from this
....ae
GP832
be misrepresenting themselves to potential customers seeking a firm that can manage and dispose of their TENO RM
wastes.
Thank you,
<george P. Partridjje Jr., Pli'JJ, P.'E.

Frankfort, KY 40601
(502) 564-6716 ext. 4651

..
2
GP833
e!~:
To:
Cc:
Subject:
Attachments:

Maze, Rodney (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Garrity, Patrick
(EEC); Stewart, Kevin (EEC); McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS
Rad Hlth)
Adv TENORM Serv - Analysis for Green Valley LF Waste.pdf
George,
I would prefer to simply share a copy of the attached ATS analysis with Dr. Ling and Mr. Hoskins and ask them point
blank, who did the analysis and where was the work performed? And if the answer is by Dr. Ling at ATS, then I would ask
to see a copy of their analytical procedures along with the determination of MDAs. We will discuss the matter on
Monday when Matt returns and decide how best to proceed. We will be sure to let you and your colleagues know our
plans.
Regards,
W?~ East Main Street

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
h1~~
n~~
ru.\DJPma1~~!41~At nt

Cc: Maze, Rodney (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Garrity, Patrick (EEC); Stewart, Kevin (EEC)
Hello Curt;
Patrick Garrity from the Division of Water (DOW) shared with us in our meeting in your offices, we can ask for the
s~orting documentation for the analytical results that were submitted to Republic Services for the Green Valley
1
GP834
initials are the same as the "Vice President" of Advanced TENORM Services.
I am concerned that we may not truly know what the characteristics are of the waste that have been disposed of at
Green Valley LF operated by Republic Services since the analytical results were provided by Advance TENO RM Services.

George
(jeorge P. Partridge Jr., Pli'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651


Hello George,
Advanced TENORM services does not have a license from our office to collect and analyze TENORM samples or any
OH. Interesting both of these companies reference the same EPA method 901.1. http://www.epa.gov/homelandsecurity-research/epa-method-9011-gamma-emitting-radionuclides-drinking-water Chris actually took photos of the
2
GP835
-ards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of u~wanted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx
11.F;1.!tM~l'"di' ~\

.ject: RE: Analytical Results Submitted by Advanced TENORM Services

.Curt;
im Status since they are new. The lab is at their company address in the Morehead Head County Public Library is
tPe'size of about two cubicles. There is no sink or water in the office and I do not see how they could run a lab at the
3
GP836
I am continuing to investigate our concerns regarding TENO RM and seek to do all I can to protect the personnel at the
George
GP837
e!~
To:
Subject:
Young, Anita (EEC)

FW: More Manifests
See below.
George Weems has requested the manifest. Talk to him.
From: Delong, Deborah (EEC)

To: Young, Anita (EEC)
Subject: FW: More Manifests

6efow. 'We wi[[ see what comes of tfiis. I
wi[[ kf,ep you postei.
~,.,,,,,,,.,,.,,,,,..,,,,,..,,,,,,,,,,.,,..,,,,,.,,,.., .. ,,,,,..,, ..,,.~..,,,.,,,,.,,,,.,,, .. ,,..,,,,,,.,,,,,,,,.. ,,,,,.,,,,,,,,,,.,.
WFrom: Weems, George (EEC)

To: Billy Bowles
Hi Billy,
GP838
e!.7:
To:
Subject:

Maybriar, Jon (EEC)
Accepted: Blue Ridge Landfill Tenorm NOV
GP839
f artridge, George (EEC)

Weems, George (EEC)
RE: RE: Confirmation of FBP - Waste Shipments
. .m:
Sent:
To:
Subject:
George;
Kevin called and shared the names of companies shipping waste to Green Valley from Ohio and he also put me in touch
with Jason Frame from WV who provided the documentation for the shipment of wastes from Fairmont Brine Processing
to Blue Ridge Landfill. As Rodney Maze and I started our investigation we identified other companies and activities of
waste from out of state involving Cory Hoskins with Advanced TENO RM Services. Kevin and Jason's contact information
is below:
Kevin Kosko
Vice President
Phone: (937) 470<-2555
lfl
SHALE
R E S 0
R C E S
Protect the futw:e, r~4 the past ...
Jason R .. Frame B ..S .. R ..T .. (R),. Chief Radiological Health Program

350Capito1Street., Room 313
Office: (304)355-4303
Fax:(304}558-0524
GP840
---------

Subject: RE: RE: Confirmation of FBP - Waste Shipments
George, how was this disposal activity discovered?

Cc:- Weems~ George (EEC); Maze, 'Rodney (EEC); Keffer, Christopher (CHFS-Rad Hlth); Anderson, Danny] (EEC); Briggs,
Lindsey (EEC)
Subject: RE: Confirmation of FBP - Waste Shipments
Curt;
On the site visit to Blue Ridge Landfill, 2700 Winchester Rd, Irvine, KY (Al 998) that was conducted by Chris Keffer,
16th 2015.
The Profile #/Contract is Y4002150 according to the Advanced Disposal records provided to us.
was received from "Cambrian Well Services" located in Norwich, OH and "Nuverra" also located in Norwich Ohio. A
'
search of the manifest to identify all TENO RM received by the facility was not conducted at this time, but will be
scheduled in the future. It is important to assess the total waste inventory of TENORM disposed of at Blue Ridge
Landfill.
BES LLC.
32 Crestview Drive
As we seek to identify landfills in Kentucky that have received TENO RM waste I am searching our TEMP0360 files and
retrieving the "Quarterly Waste Quantity Reports" for our landfills. Please find attached the "Waste Received Quarterly
Muskingam, OH only shipped 1.24 tons to Blue Ridge and it was used as "Alternate Daily Cover" reported in the
.,
'
Kentucky.
2
GP841
.reported on their quarterly waste reports.
- l s o appears that the TENO RM waste being received by this landfill/Advance Disposal from other companies is also
not being reported as well on their quarterly reports.
leave the facility. The exposure could potentially result in excess cancer risk that would manifest itself in future years in
waste.
tons of waste from Fairmont Brine Processing was applied as "Alternate Daily Cover" at the landfill which makes
to Kentucky.
I am working to identify all the company names that Cory Hoskins is using and how he is identifies the waste he is having
shipped from Kentucky from out of state and identifying additional companies that may be shipping waste containing
TENO RM as well.
~nk you again for all you and your Branch is doing to take the initiative on this investigation into TENORM that is
tined for our landfill.

George
(jeorge P. Partric{ge Jr., PfiV, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP842
Gitt in W~st Wgm!.a

f.airmi:mtia a.~ity in Mario11 Cooiity, \VestWgioia, U!iile.d Sta!~s. The
popu!ati>Dnwas Hl 704 at the 2010 censtis. it is the eoorrty seal of Marion
County.V!llkiped!3
..
::.-/''"
/ ..,.
.
....
,v. ,
-~'
;:
'- '.- i
-. : .' - '
r.f~ ~~HHpSg!e
Norwich
Village in Ohio
NQi"Wich isa village Lin Muskrngum Cqunfy, Ohio, United Stat~s Thtt
populatfoli
102 at I.he 2010 censu.tt Wifl:i~i;a
was
GP843
9rtridge, George (EEC)

.From:
Sent:
To:
Subject:

Weems, George (EEC)
RE: More Manifests
George;
Thanks for following up on this for me.
George

To: Billy Bowles
Hi Billy,
. for him? PDF'ing and emailing them would be fine. You have to keep the attachments under 8 meg per email
ugh. Thanks, George
GP844

.From:
Sent:
To:
Subject:

RE: 4127 Green Valley No 80 CAMC_2016-02-05
Curt;
Thank you for copying me.
Have a nice weekend!
George

To:
Chlebowy, William; Cecil, Kim (KCecil@republicservices.com)
Cc: Bhattacharyya, Anjan; Frame, Jason R (Jason.R.Frame@wv.gov); Keffer, Christopher (CHFS Rad Hlth); Partridge,
George (EEC)
Subject: FW: 4127 Green Valley No 80 CAMC_2016-02-05
910Bill,
.Yes I would have to agree, the attached spectra most definitely looks like the radiation portal alarm on the load of
wastes from the Charleston WV Area Medical Center was due to Tc-99m on Peak Easy analysis. And with a 6 hour halflife, I would have to presume the waste is fairly fresh. If memory serves me correct, this is the second time a medical
facility in WV has sent radioactive wastes to Green Valley Landfill in Ashland, KY. Obviously, these NRC licensed medical
facilities are not doing a good job of segregating and surveying their medical waste prior to disposing of this material in
the regular trash. I am including Jason Frame with the WV Radiological Health Program and our Regional Agreement
State Officer, Ms. Monica Ford on this e-mail in hopes that they might follow-up on this. I have talked to.our fellow
members of the Central Midwest Interstate Low-Level Waste Compact in IL and they evidently have the same problem in
their state with the occasional out-of-state medical waste shipment setting off a radiation portal monitor at a landfill in
IL. Our IL colleagues agreed that at long as we determine that the alarm is due to short-lived medical isotopes, then
disposal of out-of-compact wastes is not an issue.
GP845
Disposal of long-lived TENO RM wastes from the oil and gas industry on the other hand is another matter entirely. Oil
and gas exploration and production fluids from hydraulic fracturing operations in non-compact states such as OH, PA,
WV and elsewhere should not be accepted for disposal in KY under any circumstances. Our KY Revised Statutes strictly
prohibit such activities and the penalties for doing so are significant.
KRS 211.863. Control of commerce of low-level radioactive waste in and out of Kentucky
(3) Naturally-occurring radioactive material (NORM) as define~ in ~S .211.8,62(8)

shall be the exclusive regulatory responsibility of the states, @:xef6'pt]l\at9"J>~k>5oi)
~\6~,J11f=~~cc~~~~:;~1a~i41i~~~i

r~dioacti vity ,frocks ?r s?ils, ~r }Jackfollnd r~di.~tion, }Jut inst~ad f~f~ts~t()
~;~~~j~[:~~~f;:a~1~t~~~t~l~i~~JiKqJggi~c~J!y.~~hilitc~ct~i coi{tt~J!ablef:er~ciili~~

offense.
2
GP846
'
.ase let me know if you have any questions or comments concerning this matter.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
z-'enhi -.~
~61!1r1,4':~.
f'.AtilATil'.JtJ
m: Chlebowy, William [mailto:WChlebowy@republicservices.com]

t: Wednesday, February 10, 2016 11:00 AM
o Pendergrass, Curt (CHFS DPH)
c: Cecil, Kim
ubject: 4127 Green Valley No 80 CAMC_2016-02-05
Hi Curt:
Just following up on some paperwork. We had a roll off box from Charleston Area Medical Center set
off the alarm last Friday, Feb 5. We set the box over to the side, scanned it with the detector, then ran
the box back over the scale about an hour later. The alarm did not go off and we disposed the load. The
Identifier identified the isotope as TC-99m, an isotope that has been identified in the past, with a
confidence level of 10. The data and scan are attached.
Same issue - an out-of-state load from a state not in the Compact sets off the detector.
_Thanks.
~R.,_
a..i\
.PUBLIC
SERVICES
We'll handle It from here.'"

William L {Bill) Chlebowy, P.E. Environmental Manager
2157 Highway 151
Frankfort, KY 40601 ~
0 502-209-3816 c 502-403-8908
w republicservices.com
GP847
3
9ertridge, George (EEC)

.From:
Sent:
To:
Subject:

RE: More Manifests
Deborah;
Thank you for all you are doing.
George

See befow. We wi[[see what comes of tliis. I
wi[[ /(g,ep you postei.
Ant: Friday, February 12, 2016 9:24 AM
...W: Billy Bowles
.Subject: More Manifests

Hi Billy,
GP848
1
rtrid e, George (EEC)

.From:
Sent:
To:
Subject:

RE: More Manifests
am kre to k[p in any way I can1 (jeorge. Let me R_now if tkre is anything efse you neei.

To: Delong, Deborah (EEC)
Subject: RE: More Manifests
Deborah;
Thank you for all you are doing.
George


See befow. We wi[[see wliat comes of this. I
wi[[ /(f.ep you postei.

To: Billy Bowles
Hi Billy,
GP849
9ertridge, George (EEC)

.rom:
Sent:
To:
Subject:

Jeri;
This in an interesting read. We do need to get some regulatory and monitoring framework in place in KY!
Thank for stopping by.
George

. l o Mr.Hall,
. e s , our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompact.org/) of which KY is a member
generated TENO RM contaminated wastes from WV, OH, PA or any other state should be disposed of here in KY. That
would include the disposal of sludge generated at your facility in KV from the processing of produced water from WV oil
and gas wells. That TENORM contaminated wastes material should not be disposed of in landfills in the Commonwealth
shall bet~e exclu~iveregulatoryrresponsibility of the states, e)(p~pt1tii~fn~;p~r~b.h,
!~~~!~~f~~l~l~ilU:~~{~ij)gf~!;cw;

GP850
radi?activity of rocks or soils, or back&1"ound radiation, but instead refers to

J'ril}felil:lls ~hoseradioactiyity is techf1:oJ9gk~lly erlhanced by controllablepract,ices
.l()r~~YIJ'!.t,!].\1J):1an Pf~ct~9es) i

($100,000). Each day of the violation or l10nfompliance shall constitute a separate
offense.
could find no registration of the company on the KY Secretary of State's website (https:Uapp.sos.ky.gov/ftsearch/ ). I
State's office and obtain the required permits necessary to operate (http://onestop.ky.gov/operate/Pages/permits.aspx
).
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of ur~~anted sources http://www.crcpd.org/StateServices/SCATR.aspx
N:t!.tl!J~. ~ ..
flAOJA"tltrN..HEAtTH

Hello Curt,
I have several questions as it relates to that. Do you interpret "region" to be different than "state"? Along those
same lines, if I am operating a disposal well in eastern Kentucky it is very probable that I am receiving some
2
GP851
.&enerates a sludge that will have some TENORM signature and part of this will have been from out of state
Wmrces. Would this rule also prohibit me from accepting out of state produced water for underground injection
. i n KY?
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
MILLSTONE
ENVIRONMENTAL
GP852
9artridge, George (EEC)

.From:
Sent:
To:
Subject:

Curt;
Thank you for copying me. This is very interesting!
George

Sent:

Hello Mr. Hall,
9,
our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompactorg/) of which KY is a member
.defined "special wastes" containing technologically enhanced naturally occurring radioactive materials generated from
generated TENO RM contaminated wastes from WV, OH, PA or any other state should be disposed of here in KY, That
would include the disposal of sludge generated at your facility in KY from the processing of produ.ced water from WV oil
and gas wells. That TE NORM contaminated wastes material should not be disposed of in landfills in the Commonwealth
shall beH1e 7xclusi".e reg1dator~ respo~si~ilityof the stat~s~ ~i2~pfi#~tpbliefs.()~
~~~l~kg~)p~~M,~~!~ti~p~~~\ 9~~~~~~~:1#~!i~~~~c1'T9rfr0 ~?~ts,i~e~~~;
r,egw.fo.r, ..~lP~f\l:in.~~nm: ; . x:~1~gs(;1:9{'sc~ Jmpgg~dmat~naim .KenJUclj,
..
!H~~~rrriJ.?lf!:J~tf4!~Btifl~w:~m'~Ci91ii~fi~{tYh~~ii21igsJt~libsp~i2~.
KRS 211.862 Definitions for KRS 211.861 to 211.869. http://www.Irc.ky.gov/statutes/statute.aspx?id=8501

materials not regulated und,er the Atomic Energy Act of 1954, as amended, whose
practices. Naturally occurring radioactive material does not includet~~ natural
ra~i.oactivity ,()frocks. or soils, ()~ backg~ound radia.tion, bl1t inste(ld ~efY:r~ t~l
~~~~~!1~~Mfi~::~~:r"~Jst~~ll!iQJ~gi~flJJy:~vij~flg~ctB~?~e>'il!roil~1Ji~ pract1~$
1
GP853

offense.
One other comment; You said that Shalewater operate_s aJ~usiriess herE:! in the Commonwealth of Kentucky. However, I
could find no registration of the company on the KY Secretary of State's website (https://app.sos.ky.gov/ftsearth/ ). I
}.
Regards,
Mailstop HSlC"A
Frankfort, KY 40621
Tel: 502"564"3700 ext. 4183
Fax: 502"564~1492
E"mail: curt.pendergrass@ky.gov
Dispose of unwanted sources http://w_ww.crcpd.org/StateServices/SCATR.aspx

Hello Curt,
I have several questions as it relates to that. Do you interpret ."region" to be different than "state"? Along those'
same lines, if I am operating a disposal well in eastern Kentucky it is very probable that I am receiving some
generates a sludge that will have some TENORM signature and part of this will have been from out of state
GP854
sources. Would this rule also prohibit me from accepting out of state produced water for underground injection
.KY?
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
GP855
.artridge, George (EEC)

.rom:
Sent:
To:
Subject:

FW: RCRA Question
From: Seadler, Donna [mailto:Seadler.Donna@epa.gov]

To: Higginbotham, Jeri (EEC)
Subject: FW: RCRA Question

Hi Jeri Here is a contact for your RCRA question.
Have a great weekend!
Donna K. Seadler
Remedial Project Manager
~erfund Site Evaluation Section
.404/562-8870
From: McKeePerez, Nancy

To: Seadler, Donna <Seadler.Donna@epa.gov>
Cc: Hardegree, Wesley <Hardegree.Wes@epa.gov>; Housley, Denise <Houslev.Denise@epa.gov>; Danois, Hector

<Danois.Hector@epa.gov>
Subject: RE: RCRA Question
Donna,
Tell her to call me. I'm going to be in the office all week next week.
Nancy McKee Perez

Life Scientist
Hazardous Waste, UST, PCB & OPA Programs
Enforcement & Compliance Branch
Resource Conservation & Restoration Division
U.S. EPA Region 4, Atlanta, Georgia
mckeeperez.nancy@epa.gov
( . 562-8674
lt=rom: Seadler, Donna

To: McKeePerez, Nancy <McKeePerez.Nancy@epa.gov>; Hardegree, Wesley <Hardegree.Wes@epa.gov>; Housley,
GP856
Denise <Housley.Denise@epa.gov>; Danois, Hector <Danois.Hector@epa.gov>
Subject: RCRA Question
HiWhen I was at KDEP this week, Jeri Higginbotham, who is a risk assessor, wanted to find a contact to talk with
in RCRA. She had a question about a company that was taking brine from oil and gas processors and
precipitating out the solids. Although she thought the oil and gas processors were exempt from RCRA, she was
wondering whether the sludges from the other company were exempt.
ls there a name I can give her of who she can talk with about it?
Thanks,
Donna K. Seadler
Superfund Site Evaluation Section
404/562-8870
I
2
GP857
.artridge. George (EEC)

Maze, Rodney (EEC)
.From:
Sent:
To:
Subject:
Rodney;
Thank you,
George

To: Maybriar, Jon (EEC); Partridge, George (EEC)
Subject: Fwd: 4127 Green Valley No 80 CAMC_2016-02-05
Rodney Maze

To: '"rodney.maze@ky.gov"' <rodney.maze@ky.gov>
Hi Rodney:
forwarded the data to the KY Radiation Health. Branch for concurrence.
GP858
1
Thanks.

Heartland Area
2157 Highway 151
Frankfort, KY 40601
0 502-209-3816 c 502-403-8908
w www.republicservices.com
GP859
'
artridge, George (EEC)
.rom:
Sent:
To:
Subject:
Maze, Rodney (EEC)

Your welcome,
Have a good weekend.
I think we are headed in the right direction. I will be on the conference call Monday morning with George Weems and
Richard Thomas.
Rodney

Subject: RE: 4127 Green Valley No 80 CAMC_2016-02-0S

Rodney;
Thank you,
9orge
~------------------------
rom: Maze, Rodney (EEC)

Sent:
Subject: Fwd: 4127 Green Valley No 80 CAMC_2016-02-0S
Rodney Maze

To: "'rodney.maze@ky.gov'" <rodney.maze@ky.gov>

Hi Rodney:
the FLIR Identifier and identified the isotope as TC-99m with a confidence level 10.GP860
1
Thanks.

Heartland Area
2157 Highway 151
Frankfort, KY 40601
0 502-209-3816 c 502-403-8908
I
2
GP861
artridge, George (EEC)
.From:
Sent:
To:
Subject:
Attachments:

Weems, George (EEC)
RE: TENORM c technically enhanced naturally occurring radioactive material
Advanced TENORM Services Company Information - 012916.pdf
George;
I printed out the pages of the website and scanned them.

They are attached.
Thank you,
George

.bject: FW: TENORM - technically enhanced naturally occurring radioactive material
.George, did you perchance download Cory's Website? If not, this may be the only evidence you have on their
About Our Company

environmental services, a company providing environmental remediation, transportation, disposal, laboratory
and consulting services to general industry, municipalities, and military and government entities.
http://advtenorm.com/about/
GP862
1
----------
I
2
GP863
rtrid e, George (EEC)

.From:
Sent:
To:
Subject:

Cleveland, Daniel (EEC)
Daniel;
Thanks for sharing this.
George
From: Cleveland, Daniel (EEC)

To: Johnson, Kari; Gaddis, Sarah (EEC)
Cc: Higginbotham, Jeri (EEC); Partridge, George (EEC)
Subject: FW: Water recycling and TENORM disposal
Kari,
,J;;i._ discussed, below is an email chain from the company wanting to utilize injection wells in Kentucky to dispose of
.duced water/production fluids that have been, for lack of a better word, separated from technologically enhanced
naturally occurring radioactive materials (TENORM). Also in this chain is the email from Radiation Health Branch
.dvising this company it is illegal to transport NORM/TE NORM into Kentucky from any state except Illinois and referring
the injection well question to HWB and SWB.
_
My understanding is that EPA has primacy over injection wells, but I don't know who that contact may be. Also, I know
DOW regulates production fluids/brine, so I think this may be a CTAB question as well.
Curt Pendergrass at CHFS may be able to answer any questions about the proposed disposal and the effects of TENO RM
on the water. George Partridge in SWB has been working with him regarding TENO RM sludges as well.
Thanks

2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
Confidentiality Notice: This communication contains information which is confidential, attorney work product and
covered by the attorney-client privilege. It is for the exclusive use of the intended recipient(s). Please note that any form of
cAbution, copying, forwarding or use of this communication or the information therein is strictly prohibited and may be
~wtvful. If you have received this communication in error please return it to the sender and then delete the
rommunication and destroy any copies.
GP864
1


Mr. Hall is asking if his company can inject "out-of-state oil and gas production fluid containing TENORM in the
company's disposal wells here in KY." Curt, in Public Health, is deferring to his colleagues in the solid and hazardous
waste divisions of the Energy and Environment Cabinet. It sounds like a question for you or Kevin. Also, Curt couldn't
find his company registered on the SOS website.
From: Pendergrass, curt (cHFsbPH)

Hello Mr. Hall,
Yes, our Central Midwest Interstate Low-Level Waste Compact (http:(/www.cmcompact.org/) of which KY is a member
generated TENORM contaminated wastes from WV, OH, PA or any other state should be disposed of here in KY. That
would include the disposal of sludge generated at your facility in KY from the processing of produced water from WV oil
of Kentucky; As for injecting that out-of-state oil and gas production fluid containing TENORM in the company's disposal
Prohibitions -- Exemption. http:l/www.Irc.ky.gov/statutes/statute.aspx?id=8502
s~~!l,b~ the ~xcll1siveregulatory responsibility of the states, ~~~~~1:tb~t~{!6:p~~sj~
i11l~a,\111111t(f&~rr~~Y.
KRS 211.862 Definitions for KRS 211.861to211.869. http://www.Irc.ky.gov/statutes/statute.aspx?id=8501

!a~i.O(l_C_ti\{it of rocks_ or soils, or background radiation, but insteadff~t'S:ffq1
~~~h 11
~,ac-c:y;,,;-~ ~~~t~9fi!f9:i~~~~ll~t~,~~ii!!9~ifi~~:~[fi~~~i!~~J~~r~~!i~~s:
KRS 211.869 Penalties. http://www.lrc.kv.gov/statutes/statute.aspx?id=8505

2
GP865
offense .
).
Regards,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
&bsite: http://www.chfs.ky,gov /d ph/radioactive.htm
~y your fees on line at https://prd.chfs.ky.gov/rad epay/
. e notified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
~
. f!ifJ~)
f'J,t:J!ttrl\i'.i~M~itTH

Hello Curt,
' e would be more than happy to share our radiation health plans and laboratory data with you.
Best,
3
GP866
Ryan Hall
Technical Director
rhall@shalewater.com.
Mobile:(724) 289-7475
Office: 855-303-9416
HILLSTONE
ENVIRONMENTAL
GP867
'
.artridge, George (EEC)

.From:
Sent:
To:
Cc:
Subject:
Attachments:

Ryan Hall
KRS 211.863 CMC statute.pdf
Your welcome Mr. Hall. I am sure my colleagues in EEC can answer all your questions regarding disposal wells. Also, my
Division Director reminded me of the fact that our Kentucky Regulatory Statute KRS 211.862 Definitions for KRS 211.861
to 211.869. (http://www.lrc.ky.gov/statutes/statute.aspx?id=8501) defines "region" as follows:
(10) "Region" means the geographical area of the state of Illinois and the Commonwealth of Kentucky;
11
Therefore your question regarding what is meant by the term "outside the region" in KRS 211.863 Control of commerce
of low-level radioactive waste in and out of Kentucky-- Prohibitions Exemption" (http://www.lrc.ky.gov/statutes/statute.aspx?id=8501) would be any state other than KY or IL.

sh~llimport naturally occurring radioactive material (NORM) from outside the
'regifl for disposal in Kentucky, or dispose of such imported material in Kentucky,
Regards,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of u~anted sources http:Uwww.crcpd.org/StateServices/SCATR.aspx
l(t!J~~....: -~
rt.AtilA'tltrNHe;U.TH
ran:
Ryan Hall [mailto:rhall@shalewater.com]
99:: Friday, February 12, 2016 11:57 AM
rro: Pendergrass, Curt (CHFS DPH)

Cc: Chance Richie; McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC);
Fowler, Kathy L (CHFS PH); Jason R Frame
Subject: Re: Water recycling and TENORM disposal
GP868
Hello Curt,
question.
Thanks again,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
wrote:
Hello Mr. Hall,
Yes, our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompact.org/) of which
strictly the Commonwealth of Kentucky and the State of Illinois. No out-of-compact generated TENORM
GP869
'
(3) Naturally-occurring radioactive material (NORM) as define~. in KR~ 211.862(8)
s,hall .be th~ ~xcl~~f ve re~ulatory res!JonsibilitY, of the states, ~xceptth~tno per~on
$h~it~~pq1f11at.t~llyipA~u~irtgradiC>active.ih~t~rial ..(N()RM) . fn~ro .o~ts~deth~.
t&io11:t~rili~Bos~<!n.fy.e11nic:!C>','r.dis,pqi;eot.sucr1iJI1POrteclrnaJeri<Uir1Keni{lcky;
if the. iwi12rtf9! gisp(J~i!tare.111(;0Il.s,ii;fe11t ,~Jth.polices of th.~c:oi:iuWsiPA
(8) "Naturally-occurring radioactive material" (NORM) rneans naturally occurring
r~dioactivityof ro~ks or spils, pr bac~gr9und radiation, but i11stead.referst(i)
W:at~ri~s Wn\:>~~1~#Cllq~ft.iv.it_y~~s, (e~hnQlogic[tlly enh.<tncefl PY co~tr9ll(lble .pr~ci\c,t~S
t9rJ?Y: J1~~E4inan pr~gjice~)i

offense .
contact me.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Be notified of proposed regulation changes https:ijsecure.kentucky.gov/Regwatch/
<image001.jpg>
3
GP870
............................-----------------From: Ryan Hall [mailto:rhall@shalewater.com]

Hello Curt,
and may be-siting future locations within your boarders.
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
GP871
'
ertridge, George (EEC)

.rom:
Sent:
To:
Subject:

Lindsey;
We will be getting some questions!
George
From:- Ryan Hall [mailto:rhall@shalewater.com]

Hello Curt,
9ank you for the prompt and informative response. To be clear, I stated in the original email that we have
.ave anything there at the present (nor have had anything in the past). The line of questioning was related to
question.
Thanks again,
Ryan Hall
Technical Director

Mobile:(724) 289-7475
Office: 855-303-9416
GP872
1
wrote:
Hello Mr. Hall,
. brines from out-of-compact operations. This office interprets "the region" in KRS 211.863 to mean
strictly the Commonwealtfi-ofKentlJcky and the State of Illinois. No out-"of-compactgenerated TENORM

radiom1clide concentrations have been increased by or as a result of human
practices. Naturally occurring radioactive material does not include the l1atural
radioac~ivitt 9f r?c~s 9f s9ils, . or ~(lckgr9~nd radiati9n'. bl}t i,nst~ad r~fers t(j
~it~$:tlM~~~l~~ft!~{t~#IeQh~l}lbgf5;~1,ly;~t}}}~~Q~d.byc9pif{J11atjlt}I)ratti~~.~

offense.
2
GP873
contact me .
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<image001.jpg>
Hello Curt,
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
GP874
3
9-rtridge, George (EEC)

.rom:
Sent:
To:
Subject:
Attachments:

20160210_130248jpg;20160210_113222jpg
Hello Curt;
I appreciate others listening to my questions regarding EPA classification of waste.
Jeri Higginbotham has located a contact in EPA who we plan to discuss issues related to this industry with. Jeri and I
plan to contact them next week.
I look forward to learning more regarding EPA's position on what qualifies under the EPA's classification of 0 & G
exploration, production fluids, and brines as special wastes.
With industries and companies processing these wastes, a new waste is generated that is significantly different than the
waste being treated .
I learn more from EPA and especially what regulations under RCRA that may be applicable to our situation with
rmont Brine Processing and similar companies, I will share it with you .
hanks for requesting support from the Office of Legal Services.
Attached a couple of photos taken of where Chris and our group were surveying. I cannot thank Chris enough for all he
did for us.
Thank you and have a nice weekend!
George

Cc: Keffer, Christopher (C,HFS Rad Hlth); McKinley, Matthew W (CHS-PH)
Hello George,
Since you first brought it up at our meeting, I have been thinking about it and I could not agree more. The EPA
classification of oil and gas exploration and production fluids and brines as "special wastes" does not apply to the
companies that are in the waste processing business. These companies take "special wastes" as feedstock and generate
ntially hazardous waste on the backend separating and concentrating those constituents. And as you said, this
des not only TE NORM but potentially heavy metals and organics. What we really need is a legal opinion from US
. P A on the matter. If EPA says the special waste provision applies only to producers and companies handling those
produced fluids without modification or further processing, then I think we have all the ammunition we need to go after
Advanced TENO RM Solutions, Fairmont Brine Processing, Shalewater Solutions and others.
GP875
1
In the meantime, I have asked my superiors to contact our Office of Legal Services to get their opinion on the matter.
And yes I agree, Chris is great person to work with and have working for you. No one puts forth more effort and does so
without ever complaining, even if means trudging around a landfill in the cold and snow.
Have a nice weekend.

Kenfucky RaOiaticfrlHealth Branch
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Uantudir~
~;~~lllJ\.l\f~
t~.~lATJttN~Jfl~PLii-I

Hi Curt;
chemicals that are present. As a result they are creating a new level of "TENO RM" waste that has not been addressed to
date. We need to investigate all the chemical constituents, those that are radioactive as well as those that are not. I
that are so much more hazardous than the initial waste stream produced from the fracking operation.
the cell where the waste from FBP was placed. It was very cold and windy with snow blowing and even moisture in our
beards freezing. No one could have worked harder or done a more thorough job than Chris did. Also the positive spirit
and the way he approacheshis work, you would have thought we were working under ideal conditions in nice
I am so grateful and appreciative for all you and your Branch/Division is doing to address the issue of radioactive waste
2
GP876
'
George
~eorge P. PartrUfjje Jr., Pfi'D, P.'E., Q'EP
~epartment for Environmental Protection

Frankfort, KY 40601
(502) 564-6716 ext. 4651

To: Pendergrass, _Curt (CHFS DPH); Stewart, Kevin (EEC)

9rick .
atrick J. Garrity
aboratory Certification Officer
Frankfort, KY 40601
Phone: (502)564-3410
Fax: (502) 564-2741


Hello gentlemen,
res
again for your assistance in this matter and please do not hesitate to contact me if you have any questions or
.comments concerning this matter.
Regards,
GP877
3

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
We_bsite: http:flwww.chfs.ky.gcJVI dph/rad ioactive. htm
Pay your fees on line at https://prd.chfs:kyioV/rad epay/
u...,... . ~
~~ ....rw'!J
f:;!\O)Jc\'r!Oi\!~H~'itTH
Brine
attatchment

Office: (304)356-4303
Fax: (304) 558-0524
I
4
GP878
.o:
Aom: Partridge, George (EEC) [mailto:George.Partridge@ky.gov]
Tent: Friday, January 29, 2016 3:48 PM

Frame, Jason R
Jason;
TENORM disposal.

know some of the above items we discussed in our conversation but I was so floored with the news I want to be sure I
George


0.e of Environmental Health Services/Radiation, Toxics and Indoor Air Division
3
apitol Street, Room 313
.harleston, West Virginia 25301
Office: {304)356-4303
Fax: {304) 558-0524
5
GP879

To: Frame, Jason R
Hello Mr. Frame,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http:l/www.chfs.ky.gov/dph/radioactive.htm
Pay your fees on line at https:l/prd.chfs.ky.gov/rad epay/
m
. . , ;),.,.)
Zl
. .n... ~.
~~~~~flt:'
1'.A~lft.110:11 Cb.Hat~t.'(}l

Mr. Pendergrass,
GP880
rating as "Advanced TENO RM Services" is continuing to facilitate the disposal of WV waste in KY landfills. Please
'Wvise on this issue. Thanks

Office: (304)356-4303
Fax: (304) 558-0524
t~;-,;;~d,~~~;~~~~
Curt (CHFS DPH) [mailto:Curt.Pendergrass@ky.gov] .

~ent: Tuesday, July 21, 2015 9:45 PM
Wfo: Frame, Jason R
Hello Mr. Frame,
is required.
Regards,

Mailstop HS1C-A
iacrort, KY 40621
lW'"phone: 502-564-3700 ext. 4183
Fax: 502-564-1492
7
GP881
herein.

Dr. Pendergrass,
Frankfort, KY 40601
Ph: 502-564-3700 x4179
Cell: 502 330-7662
FAX: 502-564-1492
I
8
GP882
eartridge, George (EEC)

.rom:
Sent:
To:
Cc:
Subject:
Attachments:
Carlton, John (EEC)

Hatton, Tony (EEC); Anderson, Danny J (EEC); Maybriar, Jon (EEC); Cleveland, Daniel
(EEC)
Aldridge, Louanna (EEC); Partridge, George (EEC); Green, Robin C (EEC); Aldridge,
Tabitha (EEC); Litchfield, Arline (EEC)
TENORM Notice to Solid & Special Waste Facilities
TENORM Notice to Solid & Special Facilities 021616.docx
Hello ALL,
Please find attached the notice to all solid and special waste facilities concerning TENO RM. I made all of Jon Maybriar's
changes and also changed the heading as well to reflect the fact that we opened the scope of the notice to include more
than just solid and special waste landfills. The heading now reads "NOTICE TO All SOLID AND SPECIAL WASTE FACILITY
OWNERS AND OPERATORS".
Finally, the Notice is dated for Tuesday, February 16th in order to accommodate Daniel's 24-hour courtesy to inform
CHFS of this notice .
ny-A printed copy is on Jennie's desk for your signature.
Thanks!
fiobt~, ~
Internal Policy Analyst IT
Commonwealth of Kentucky
Program Planning & Administration Branch
Program Development Section
200 Fair Oaks Lane, 2nd floor
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049
~hink
before you Ink
Please consider the environment before printing this email.

1
GP883
.rtridge, George (EEC)

.rom:
Sent:
To:
Subject:

Curt;
If we can show that an industry that takes the waste produced from the 0 & G industry, etc. and processes it to
produce a product or waste that is substantially different from the source material and is no longer classified as a
"special waste", that would open the door for us to address our concerns from a multitude of regulatory
perspectives.
I am continuing to pursue things from my Section and Division.
Thank again for all you are doing!
George
rom: Pendergrass, Curt (CHFS DPH)
ent: Friday, February 12, 2016 12:11 PM

Hello George,
But having said that, I am confident that our cabinet will pursue this matter to the fullest extent of the law.

Apervisor, Radioactive Materials Section
Mailstop HS1C-A
Frankfort, KY 40621
GP884
1
Tel: 502-564-3700 ext. 4183

Fax: 502-564-1492
Be notified of proposed regulation changes https:l/secure.kentucky.gov/Regwatch/
Vnn(U~
t~t.~~w
MttlAT10N4HEPJ.TH

Curt;
Dr. Ling has used his reputation and skills to support the activities of Advanced TE NORM Services. It appears that
to be using Advanced TENORM Services to attract business from out of state for companies that are searching for an
things for him: 1) TENORM is not mentioned in the correspondence or the name of the company that the landfill or
waste.
I want to do all I can to support the work that you and your Section is doing to safely manage and regulate TENORM.
GP885
'
ediation safety as well as the site visits he has conducted .
Geroge

Frankfort, KY 40601
(502) 564-6716 ext. 4651
Aom:
~ent: Tuesday, February 09, 2016 8:13 AM
say about the Central Midwest Compact and its ban on the disposal of out-of-compact TENORM wastes in KY. But
penalties. At some point we probably need to get EEC1s and CHFS's lawyers involved in this matter for a legal opinion
Regards,
Curt

GP886
3

offense.
211.862 J)~fi.l!iti()J1_[Qrl{RS 21L8~ to ~11.869. http://www.Irc.ky.gov/statutes/statute.aspx?id=8501

, --~--
~adioacti\'ity ?.frocksor s?ils': ?r ~ack~r7u~d radiation, but inst~~d i~t@:CJ,
~f~~tt~~R~~aM~lf:~ti~i~~~~~isJe2tlii9f~g19~11i ~frhatibyq.~y29ntrol1~B,1e'pfa6ti~es,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564~3700 ext. 4183
Fax:502-564-1492
Be notified of proposed regulation Changes https:Usecure.kentucky.gov/Regwatch/
,~~
/(!!Jt#jjf!j ..
f~01fo.TION~H~<1TH


4
GP887

9ubject: RE: New Comment from KLYSTAR.com
Hi George,
.... I am currently on vacation, back Thursday. Cory Hoskins is KLYTEC business partner on TENO RM issues as it relates
to hydraulic fracturing produced wastes, and he or my other KL YTEC colleagues can assist you as needed during my
absence.
Leong
Dr. Leong Ying

KL YTEC - President
Mobile: 212 203 5842
'111111111ient:

klystar@hotmail.com
Hi Leon,
First
George
name:
Last
name:
Partridge
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
A
W
Comment:
GP888
5
Kind Regards
George Partridge

I
6
GP889

.rom:
Sent:
To:
Subject:
Attachments:
Maze, Rodney (EEC)

Pendergrass, Curt (CHFS DPH); Partridge, George (EEC)
image002.png
Good afternoon,
Is there anyway to find out who the landfill operator and facility was that approached Ryan Hall with a
competitive bid for disposal.
Thanks
Rodney
Rodney Maze
On Feb 12, 2016, at 4:44 PM, Bevins, James (EEC) <James.Bevins@ky.gov> wrote:
FYI. Keeping you in the loop.

To: Fraley, Daniel (EEC); Gaddis, Sarah (EEC); Huffman, Lance (EEC)
Cc: Bevins, James (EEC); Johnson, Kari
Thanks Danny,
I've asked Lance Huffman in my office to coordinate any need for DOG involvement with the request
below because he handles a lot of the DOG issues. We will likely be interested in the list of UIC wells.
Would it be fair to refer the requesting company and CHFS - RHB to the contacts below for further
consultation?
. Office of General Counsel
2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
Confidentiality Notice: This communication contains information which is confidential, attorney work
product and covered by the attorney-client privilege. It is for the exclusive use of the intended recipient(s).
Please note that any form of distribution, copying, forwarding or use of this communication or the
information therein is strictly prohibited and may be unlawful. If you have received this communication in
error please return it to the sender and then delete the communication and destroy any copies .
From: Fraley, Daniel (EEC)
GP890
1
To: Gaddis, Sarah (EEC); Cleveland, Daniel (EEC)

Daniel: Here is the most updated information on the UIC contacts for the Morehead Regional
Office. These are very subject to change. If any of the numbers that were are referencing you too are
not good, please let us know and we will run down the numbers. It might be good to contact the
Division of Oil and Gas they might have additional numbers and contacts to address any questions you
may have as to the disposal of RAD waste in UIC wells.
Si rice p-rimacy Iles with EPA on inspecting these wellsthe point of contact for the regional contract
inspector is:
-Bill Mann is/was a UIC inspector for EPA Region 4: 404-562-9452
The contract UIC inspectors for EPA Region 4 in KV are/were Carl Weller and Red Fox. However,
I never met these guys and don't have their phone numbers. I'd say someone with DOG has
them so let me know if we need them.
For specific questions related to UIC wells our point of contact with EPA is:
- Carol Chen is/was a Groundwater Enforcernent Specialist for EPA Region 4. Her number
is/was: 404-562-9415
In addition my inspector gave me list of UIC wells for the Morehead Region in case you are
interested. You can filter to the active sites in the excel spreadsheet.
Thanks
Dan Fraley
From: Gaddis, Sarah (EEC)
Sent: Friday, February 12, 2016 12: 11 PM

To: Fraley, Daniel (EEC)
Danny,
Will you give Daniel the rundown on this issue, please?
Thank you,
Sarah

Kari,
2
GP891
As discussed, below is an email chain from the company wanting to utilize injection wells in Kentucky to
dispose of produced water/production fluids that have been, for lack of a better word, separated from
technologically enhanced naturally occurring radioactive materials (TENORM). Also in this chain is the
email from Radiation Health Branch advising this company it is illegal to transport NORM/TE NORM into
Kentucky from any state except Illinois and referring the injection well question to HWB and SWB.
My understanding is that EPA has primacy over injection wells, but I don't know who that contact may
be. Also, I know DOW regulates production fluids/brine, so I think this may be a CTAB question as well.
Curt Pendergrass at CHFS may be able to answer any questions about the proposed disposal and the
effei:ts of TENORM on the water. George Partridge in SWB has been working with him regarding
TENO RM sludges as well.
Thanks

2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
product and covered by the attorneycclient privilege. It is for the exclusive use of the intended recipient(s).
error please return it to the sender and then delete the communication and destroy any copies.

Mr. Hall is asking if his company can inject "out-of-state oil and gas production fluid containing TENO RM
in the company's disposal wells here in KY." Curt, in Public Health, is deferring to his colleagues in the
solid and hazardous waste divisions of the Energy and Environment Cabinet. It sounds like a question
for you or Kevin. Also, Curt couldn't find his company registered on the SOS website.

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge, George (EEC);
Fowler, Kathy L (CHFS PH); Frame, Jason R (Jason.R.Frame@wv.gov)
Hello Mr. Hall,

brines from out-of-compact operations. This office interprets "the region" in KRS 211.863 to mean GP892
3
from WV oil and gas wells. That TENORM contaminated wastes material should not be disposed of in
containing TENORM in the company's disposal wells here in KY, I am going to have todefer to my
plans and laboratory data" .
. KRS 211.863 Control of commerce oflow-level radfoactive waste in ana out of Kentucky
(3) Naturally-occurring radioactive material (NORM) as define4 inl(J{S 211.862(8)
sh~llbe t~e exclusive reg~latory responsi?ility ofthe states, x~.ypft~~i. pers.61\
ii9
~m~m~~i~tl!i}itt~~~3rttt!IJi~~rl~:.~ky,
KRS 211.862 Definitions for KRS 211.861 to 211.869.
~a~i:acti~ity . ()f rocks or.soils,. orb~ckground radi~tion, ~mt inst~ad ~~f~j~J~ .. ..
~lf~~~iirrkd~~~}~~tM~~f,1~t~~li,Ji(j1p~i,aiJy:~~Ji~iis&4.~~fg~r~r91~~liiy11r~stkefs
KRS 211.869 Penalties. http://www.lrc.kv.gov/statutes/statute.aspx?id=8505
(1) Any person who fails to col)lply with any provision of KRS 211.859 or 211.863, or
offense.
contact me.
Regards,

Mailstop HSlC-A
4
GP893
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<imageOOl.jpg>

Hello Curt,
disposal. We were then llQtified that 211.863 prohibits disposal of NORM from outside of the
~w~vis~y~l'af~l1~sJi6~0saslt~elat~.t()1:~~t.ciJ,?o ..y9l1lnt~rpret'''r~gi~n".tobe . diffete~t.!~~!1.
~'staf~''.7c ~of\g !llp~esan,ie lieS:, WI~opeq1ting>a ~jsposal. .\\'elJ. i~ ~ast~xn:K~ptyc;~:yt i~A~Hy
B~<!~~W~!h~t(~~~e9eiY!.ri~'.~Je:pr6~ce~:watei-fr9rriwvwells.{.g~nera!Jypfajtofiy
~~lil~iES~i~l~~1{:~~~~i~~t;if~~1~~~q:~~~$~~
Best,
Ryan Hall
Technical Director

Mobile:(724) 289-7475
Office:
855-303~9416
~I HILLSTONE
ENVIRONMENTAL
GP894
5
9artridge, George (EEC)
.rom:
Sent:
To:
Subject:

RE: WW Application and QAP for Advanced TENORM Services
Curt;
The DOW has a very different impression of their laboratory capabilities as described in the application material and
what was observed by our site visit. They are only certified for TSS, O&G, and pH for wastewater, but their description
of their laboratory, staff, etc. gives the impression of a very nice laboratory facility.
I am just sharing the documents to continue to demonstrate that as a company they have misrepresented their
capabilities.
If they were to do all they claim in their application, they would be placing the public and employees in the library at risk
for exposure.
DOW is investigating their laboratory.
~rom: Pendergrass, Curt (CHFS DPH)

~ent: Friday, February 12, 2016 12:44 PM

Cc: Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHSPH)
Subject: RE: WW Application and QAP for Advanced TENORM Services
Thanks George. I didn't see anything in their Wastewater Laboratory application regarding the analysis for radionuclides
at their rented office in the Morgan County Public Library. Obviously, based on the presence of radioanalytical
equipment at this office in West Liberty that both you and Chris took pictures of, this rented space is being used for
activities not covered by the DOW permit. And yes, where do they clean their TENORM contaminated lab equipment
and dispose of their TENORM contaminated lab wastes?
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
"W115ite: http://www.chfs.ky.gov/dph/radioactive.htm
P~our fees on line at https://prd.chfs.ky.gov/rad epay/
.Be notified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
GP895
1

Cc: Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Keffer, Christopher (CHFS Rad Hlth)
Subject: FW: WW Application and QAP for Advanced TENORM Services
Curt;
in the Morgan County Public Library where there appears to be no sink or running water, only an partitioned office area
with the door labeled "B" on the front, no company name. I do not see how he could be running a laboratory from this
be misrepresenting themselves to potential customers seeking a firm that can manage and dispose of their TENORM
wastes.
Thank you,
George
(jeorge P. Partridge Jr., Pfi'D, P.'E.

Frankfort, KY 40601
(502) 564-6716 ext. 4651

GP896

.rom:
Sent:
To:
Subject:
Attachments:
Bevins, James (EEC)

Maze, Rodney (EEC); Partridge, George (EEC)
FW: AI#l25200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Advanced Tenorm Services COC & analytical results for AI 2631.pdf
FYI.

To:
Gaddis, Sarah (EEC); Hall, Frank (EEC)
Cc: Bevins, James (EEC)

Subject: FW: AI#125200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Sarah/Frank: Thought you all might be interested since we have discussed this in the .past. Good catch on James part
during the inspection.
James intends to discuss this with Eric Cole/Wells Group in the future, any suggestions on how we approach this?
. n k did the lab lose its certification on 01/01/15 or is James correct in saying 01/01/2016?
Thanks
. a n Fraley
From: Bevins, James (EEC)

To:
Fraley, Daniel (EEC)
Subject: RE: AI#l25200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Danny,
Thanks for the update. I was doing a KYG11 CEI at the Louisa Wells Group Ready Mix facility today (Al 2631) and
requested the most recent COC and analytical reports. They are attached. Apparently, the Wells Group is doing their
own pH and are field certified for this. However, Advanced Tenorm Services is their lab for TSS and O&G. The last
samples were collected prior to their certification expiring on Jan. 1, 2016 (per Frank Hall's e-mail below). The Louisa
Wells Group hasn't collected samples for the 1st quarter 2016 yet. With that said, I intend to discuss this with Eric Cole
(Env. Coordinator for Wells Group) and make sure his 1st quarter 2016 samples are analyzed by a certified lab another
that Advanced Tenorm Services. At present, we can't cite them for not complying with the WW lab certification
requirement. Do you see anything I'm missing here? Keep in mind that there are multiple Wells Group locations in our
region that this will apply to.
Thanks,
James
............. ....... ,...,.,..................... ;,

,.,
m: Fraley, Daniel (EEC)
~ent:

Bevins, James (EEC)
To:
GP897
1
From: Hall, Frank (EEC)

To: Fraley, Daniel (EEC); Gaddis, Sarah (EEC)
Subject: RE: AI#125200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Sara/Dan,
We took a look at this after our conversation. Advanced TENO RM Services KY08061 is no longer certified as of January
1, 2015 for failure to renew:The Laboratory Certification Section is going to request a data package to determine reproducibility. We will keep you in
the loop.
Frank Hall
Kentucky Laboratory Certification

To: Gaddis, Sarah (EEC); Hall, Frank (EEC)
Subject: AI#125200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Sara/Frank: As we discussed on the phone this morning. DWM has some significant issues with this facility regarding
waste disposal issues. These DWM issues are not relevant to DOW at this time. What is relevant to DOW right now is
the lab certification that the facility has as interim. Attached are pictures that were taken by DWM on 02/04/16 during
their investigation. Advance TENO RM has been working on lab certification since early on in 2015. Information about
the certification application and parameters are detailed in the Al# 125200.
As you can see by the pictures that lab is located in the public library in West Liberty. Some lab equipment is visible in
the photos. The address of 32 Crestview Drive according to Google earth places you near the airport in West Liberty.
Frank: As we discussed, I will be than willingto accompany you on your inspection/audit of the facility. We have a
vehicle here in the Morehead office that we can use. Just work out the details on your end and we will get this done
ASAP.
If you all have any questions just let me know and I will get you all answers.
Thanks
Dan Fraley
From: Hall, Karen (EEC)

Subject:
GP898
.tridge, George (EEC)

.From:
Sent:
To:
Subject:

Maze, Rodney (EEC); Partridge, George (EEC)
Not that I am aware of gentlemen. This is way outside my lane. I guess you could come right out and ask Mr. Hall but
that might tip him and the landfill off.
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
.
Anotified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
Wspose of unwanted sources http://www.crcpd.org/StateServices/SCATR.aspx
l(_enm .~~)
t1Ao;titi~HiU~i}t:H

To: Pendergrass, Curt (CHFS DPH); Partridge, George (EEC)
Good afternoon,
Is there anyway to find out who the landfill operator and facility was that approached Ryan Hall with a
Thanks
Rodney
Rodney Maze

GP899
1
Thanks Danny,
I've asked Lance Huffman iTJ my office to coordinate any need for DOG involvement with the request
below because he handles a lot of the DOG issues. We will likely be interested in the list of UIC wells.
consultation?

Offiee of General Counsel
2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212

Since primacy lies with EPA on inspecting these wells the point of contact for the regional contract
inspector is:
The contract UIC inspectors for EPA Region 4 in KY are/were Carl Weller and Red Fox. However,
- Carol Chen is/was a Groundwater Enforcement Specialist for EPA Region 4. Her number
is/was: 404-562-9415
2
GP900
Thanks
Dan Fraley

Danny,
Thank you,
Sarah


Kari,
email from Radiation Health Branch advising this company it is illegal to transport NORM/TENORM into
effects ofTENORM on the water. George Partridge in SWB has been working with him regarding
TENORM sludges as well.
Thanks

2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
GP901
3

Mr. Hall is asking if his company can inject "out-of-state oil and gas production fluid containing TE NORM

Hello Mr. Hall,
from WV oil and gas wells. That TE NORM contaminated wastes material should not be disposed of in
~hal! b~the excl~siv~.regulato~ responsibili.t~.of the ~tates., ~~~~~pl,!~.~t?9fJ.ef~qp
~i~1~r1~1r111~i~l~~~t~111ifrt11~~~~~~,
ra~i?~ctivity of rocks or soils, or b~ckground radiation, but inst~adr&f~t&:~tQ1
!t~~~~~~l{N~~1tWI~"~. .i1~fhg6JQ~~~.~1Jy~~}ih@g~~fjy;q~Jt2ii~~t~:'.~t~~x1~~,
KRS 211.869 Penalties.http://www.lrc.ky.gov/statutes/statute.aspx?id=8505
4
GP902
offense.
contact me.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<image001.jpg>

Hello Curt,
GP903
5
We would be more than happy to share our radiation health plans and laboratory data with you .
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
HILLSTONE
ENVIRONMENTAL
GP904

.rom:
Sent:
To:
Subject:

Curt;
Internally, in our Division, we are concerned with the quality of analytical work that was submitted by ATS to Republic
Services. We want to know who did the analytical work? Was it a certified lab? Do we have data or supporting
documentation for the analytical work and chain of custody paperwork, etc.?
I look forward to learning how you and Matt decide to proceed. Please let us know if there is anything we can do to be
supportive.
Thank you,
George

Ait: Friday, February 12, 201612:49 PM

,
Cc: Maze, Rodney (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Garrity, Patrick (EEC); Stewart, Kevin (EEC);
AMcKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth)
subject: RE: RE: Analytical Results Submitted by Advanced TENORM Services
George,
I would prefer to simply share a copy of the attached ATS analysis with Dr. Ling and Mr. Hoskins and ask them point
blank, who did the analysis and where was the work performed? And if the answer is by Dr. Ling at ATS, then I would ask
to see a copy of their analytical procedures along with the determination of MDAs. We will discuss the matter on
Monday when Matt returns and decide how best to proceed. We will be sure to let you and ypur colleagues know our
plans.
Regards,
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
ii: curt.pendergrass@ky.gov
site: http://www.chfs.ky.gov/dph/radioactive.htm
.Pay your fees on line at https://prd.chfs.ky.gov/rad epay/
GP905
1
7/n:u(U"CJi~
1~.fJ.NAl~~rw,
11.Att};\\Tl\JNeAHiALrH

Cc: Maze, Rodney (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC); Garrity, Patrick (EEC); Stewart, Kevin (EEC)
Hello Curt;
what Patrick Garrity from the Division of Water (DOW) shared with us in our meeting in your offices, we can ask for the
supporting documentation for the analytical results that were submitted to Republic Services for the Green Valley
initials are the same as the "Vice President" of Advanced TENORM Services.
I am concerned that we may not truly know what the characteristics are of the waste that have been disposed of at
Green Valley LF operated by Republic Services since the analytical results were provided by Advance TENORM Services.
George
(jeorge P. PartridiJe Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651

GP906
Hello George,
'vanced TENO RM services does not have a license from our office to collect and analyze TE NORM samples or any
.amples suspected of being contaminated with radioactive materials. I believe the company has an office in Ohio so I will
OH. Interesting both of these companies reference the same EPA method 901.1. http://www.epa.gov/homelandsecurity-research/epa-method-9011-gamma~emitting-radionuclides-drinking-water Chris actually took photos of the
testing laboratory, including those that analyze for radionuclides. But botto.m line, if Pace Analytical and ATS were
Regards,
Atucky Radiation Health Branch
~ East Main Street
Mailstop HS1C-A
.rankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
. -. . . ~~
.... :>

Curt;
v9eviewed manifests during our site visit and identified wastes being sent from Ohio with the paper work signed by
presented, I do not understand the need to ship the waste to Kentucky at a higher cost to the company. GP907
3
radioactive illCl_t~riC!_Ls \i\fO_l11d llE! ve~yhelpful.
George
GP908

.From:
Sent:
To:
Subject:

RE: RCRA Question
Jeri;
Thank you!
George

From: Seadler, Donna [mailto:Seadler.Donna@epa.gov]
Ait:
W: Higginbotham, Jeri (EEC)

. H i JeriHere is a contact for your RCRA question.
Have a great weekend!
Donna K. Seadler
404/562-8870
From: McKeePerez, Nancy

To: Seadler, Donna <Seadler.Donna@epa.gov>
Cc: Hardegree, Wesley <Hardegree.Wes@epa.gov>; Housley, Denise <Housley.Denise@epa.gov>; Danois, Hector
<Danois.Hector@epa.gov>
Subject: RE: RCRA Question
Tell her to call me. I'm going to be in the office all week next week.
Nancy McKee Perez
GP909
1
Life Scientist
Hazardous Waste, UST, PCB & OPA Programs
Enforcement & Compliance Branch
Resource Conservation & Restoration Division
U.S, EPA Region 4, Atlanta, Georgia
mckeeperez.nancy@epa.gov
(404) 562-8674
From: Seadler, Donna

S~n!: FrigayL~~rl1ary 12, ?O~~ 2:5_? PM
To: McKeePerez, Nancy <McKeePerez~Nancv@epa.gov>; Hardegree, Wesley <Hardegree.Wes@epa.gov>; Housley,
Denise <Ho..usley.Denise@epa.gov>; Danois, Hector <Danois.Hector@epa.gov>
Subject: RCRA Question
HiWhen I was at KDEP this week, Jeri Higginbotham, who is a risk assessor, wanted to find a contact to talk with
in RCRA. She had a question about a company that was taking brine from oil and gas processors and
precipitating out the solids. Although she thought the oil and gas processors were exempt from RCRA, she was
wondering whether the sludges from the other company were exempt.
Is there a name I can give her of who she can talk with about it?
Thanks,
Donna K. Seadler
404/562-8870
e
I
GP910

.rom:
Sent:
To:
Subject:

I definitely agree George. I think you hit the nail right on the head when you first mentioned that at our meeting. I
personally believe that is a call for the EEC hazardous waste and the US EPA. I thought your colleague was going to
check into that for us with her EPA contacts. John Richards is the only person at EPA that I have ever dealt with
regarding rad and she indicated that John only handles risk analysis for EPA.

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564~3700 ext. 4183
Fax:502-564-1492
mail: curt.pendergrass@ky.gov
ebsite: http://www.chfs.ky.gov/dph/radioactive.htm
KIZW

Curt;
If we can show that an industry that takes the waste produced from the O & G industry, etc. and processes it to
perspectives.
9n
continuing to pursue things from my Section and Division .
GP911
George
1

Hello George,
I could not agree more with everything you say afiol..ltDr. ling, Mr~ HOskins a-nd theirac::tiVities~This mostdefinitely--- should not go unpunished. One comment I would make though regarding EEC's authority. My reading of the statute
such waste is source, special nuclear or by.. product material as defined by

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.kv.gov/dph/radioactive.htm
Pay your fees on line at https://prd.chfs.ky.gov/rad. epay/
/LeJttM~
i"".AtilATJtH~~H~M..tH

Curt;
GP912
Dr. Ling has used his reputation and skills to support the activities of Advanced TENORM Services. It appears that
9ory Hoskins has two businesses incorporated out of his home, BES LLC and Advanced TE NORM Services. He appears
attractive cost solution to their TE NORM disposal needs. He is using the BES LLC company name and signing off as
waste.
Aaste and all enforcement would need to come from your Cabinet. At the same time today I learned we do plan to
~ke action to let our waste management facilities around the state know about this waste that is being shipped and
Geroge
<;jeorge P. PartridiJe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP913
3

To: Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hltli); Maze, Rodney (EEC); Hall, Karen (EEC)
say c:ibout t.he Central Midwest Compact and its ban on the disposal of out-of-compact TENO RM wastes in KY. But
now that we know he is ciil-ectly-in\/olved, that will give us scfrneone else to go after should we pursue fines and
Regards,
Curt

(3) Naturally-occurring radioactive material (NORM) as defin~din ~~}~l . 862(8)

shall ?ethe ~x~lusi'le ~e.gul.~toryr~sp?n,sibility ?!.t.~e. st'1te~: ~xse,Btfhat. JilliP~~.~6!l
~ft!11fll~~tl#l~ilil't~l~lf~l~~~ky,
offense.

~adioacti\rity .?f roc~s ~rs?il~,. orb.ack~round radi~tion:but inst~a~ ief~rf!~
:.m~~~~t,.~r.J~~wt:~.ft~'.~~c'.)~..~~g~ctJfxti. ~"i~J~Mwli!2'gi~~11lf~n1i~iis~~J;~G'ciri1r~ll<l!Jl~i)i-'!6t~c~s'.
..
11
oru'lr.pas umanprac 10es\,

c_:_,,\;).?,
,,_ -"",:;~ ~.- .,J~-;J_-> ~-<: o:-._:;,.c~,:_-_',. ;.. _~::,~;'.<.,.'.._",'>'
_,, ' '"'-,.,s-

4
GP914
A75 East Main Street
wiviailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
'
Fax:502-564-1492
Website: http://www.chfs.ky .govId ph/radioa ctive. htm
Ven(Uf/;r~
1~6'n.~~~~
f.AIJJAT}O!'~~}l~<t:n1


Hi George,
absence.
Leong
GP915
5

Hi Leon,
First
George
name:
Last
Partridge
name:
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
Comment:
Kind Regards
George Partridge
~------~---------~--------------------~----~----~~-------------------~----------------------------~--

Checked by AVG - www .avg.com
e
6
GP916

.rom:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney;
Thank you for being there today for our meeting. I look forward to our conference call Monday.
We both bring important perspectives to this situation and I appreciate so much having the opportunity for us to work
together!
George

.ject: RE: 4127 Green Valley No 80 CAMC_2016-02-05

Your welcome,
. a v e a good weekend.
.
I think we are headed in the right direction. I will be on the conference call Monday morning with George Weems and
Richard Thomas.
Rodney

Subject: RE: 4127 Green Valley No 80 CAMC_2016-02-05

Rodney;
Thank you,
George

Subject: Fwd: 4127 Green Valley No 80 CAMC_2016-02-05
.odneyMaze
GP917

1

To: '"rodney.maze@ky.gov"' <rodney.maze@ky.gov>
Subject: FW: 4127 Green Valley No 80 CAMC_2016-02-0S
Hi Rodney:
Health Branch doesn't-have the resources to respond to each alarm and they have allqwed _
Thanks.
William L. {Bill} Chlebowy, P.E.
Heartland Area
2157 Highway 151
Frankfort, KY 40601
0 502-209-3816 c 502-403-8908
GP918

.From:
Sent:
To:
Subject:

Curt;
Thank you!
George

To: Ryan Hall
Your welcome Mr. Hall. I am sure my colleagues in EEC can answer all your questions regarding disposal wells. Also, my
Aision Director reminded me of the fact that our Kentucky Regulatory Statute KRS 211.862 Definitions for KRS 211.861
11
'211.869. (http:Uwww.lrc.ky.gov/statutes/statute.aspx?id=8501) defines region" as follows:
(10) "Region" means the geographical area of the state of Illinois and the Commonwealth of Kentucky;
Therefore your question regarding what is meant by the term "outside the region" in KRS 211.863 "Control of commerce
of low-level radioactive waste in and out of Kentucky-- Prohibitions Exemption" (http://www.lrc.ky.gov/statutes/statute.aspx?id=8501 ) would be any state other than KY or IL.
(3) Naturally-occutring radioactive material (NORM) as defined in KRS 211.862(8)
shall import naturally occurring radioactive material (NORM) from t:i:qt:~i~~\tll~
{~gfo'.1!1 for disposal in Kentucky, or dispose of such imported materiai~in ~Ke~ntucky,
Regards,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
.02-564-1492
1
GP919
tu
.... .ac.~.
g
u..n.M.
'~-3
Mf:JlATlOl~~-HMLTH

Hello Curt,
question.
Thanks again,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
HILLSTONE
ENVIRONMENTAL
wrote:
Hello Mr. Hall,
strictly the Commonwealth of Kentucky and the State of Illinois. No out-of-compact generated TE NORM
2
GP920
(3) Naturally-occurring radioactive material (NORM) as definedinK_RS21L8~2(8)
shll! ~~ t~~ ~;'Cf.!\ls!\T~ regl1latoEy r~~J?()ns~Wlity of.the states, ~xcf~ptth~fj.~f>.ZIJr;~9n
~.hai1 'itiJg()rtn!\t~~a,1Jyc().Sttr,~11g:fa4i()~c#.~epiaterla,l .(~9~);Ir6~ oiltsid.~ th~. . .
}tf~~l~~1~~1fl~~~~~~i6~J~{f;f&s~tltl'~d?de~~~7h~~&=~}~fi,~eritc~,:

(8) "Naturally-occurring radioactive material'; (NORM) means naturally occurring
practices. Naturally occurring radioactive material does not include t~~.natural
~l~i~e~ti.\Ti!J'1()f.~.()~~~s.8~ sg.H~? ()~}Jack~()Un~ ra~i(lti().~,.u! i~~!ead r,~f~f~'t~, ..... :

~l!t~~~~t{~l,~i~~~f~~~~t:iJ~h!!qJRg!i;aJJy.~nh.<tn~~9 :by ~9gti0Jlll>1~1nt~gti.e~
offense.
necessary to operate (http:ljonestop.ky.gov/operate/Pages/permits.aspx ).
contact tne.
Regards,

Mailstop HSlC-A
Frankfort, KY 40621
GP921
3
Tel: 502-564-3700 ext. 4183

Fax: 502-564-1492
Pay your fees on line at https:ljprd.chfs.ky.gov/rad epav/
<imageOOl.jpg>
From: Ryan.Hall imailto:rball@shalewater.com]

Hello Curt,
TEN ORM signature and part of this will have been from out of state sources. Would this rule
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
GP922

Carlton, John (EEC)
RE: TENORM Notice to Solid & Special Waste Facilities
.rom:
Sent:
To:
Subject:
Tracking:
Recipient
Delivery
Carlton, John (EEC)
Delivered: 2/12/2016 5:46 PM
John;
I appreciate all that you and Louanna are doing to address our concerns regarding TENO RM disposal at our landfills, etc.
I reviewed the letter and offer the following comment for consideration:
Waste disposers claim the special waste exemption under RCRA and to do so include the words or abbreviation of "O
& G" in the name or description of the waste. The waste is often labeled "sludge" or "tank bottoms" along with the
abbreviation for the oil and gas or oil and gas exploration waste industry included .
anks again for all you are doing.

Have a nice day!
.eorge
From: Carlton, John (EEC)

To: Hatton, Tony (EEC); Anderson, Danny J (EEC); Maybriar, Jon (EEC); Cleveland, Daniel (EEC)
Cc: Aldridge, Louanna (EEC); Partridge, George (EEC); Green, Robin C (EEC); Aldridge, Tabitha (EEC); Litchfield, Arline
(EEC)
Subject: TENORM Notice to Solid & Special Waste Facilities
Hello ALL,
Please find attached the notice to all solid and special waste facilities concerning TE NORM. I made all of Jon Maybriar's
than just solid and special waste landfills. The heading now reads "NOTICE TO ALL SOLID AND SPECIAL WASTE FACILITY
CHFS of this notice.
Tony-A printed copy is on Jennie's desk for your signature.
i.Pt*
e n ks!
';?I,
~
GP923
Internal Policy Analyst II

1
-Frankfort,Kentucky40601
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049
,,t
think before you ink

GP924

.rom:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney;
Thank you for copying me on this. I see companies like Fairmont Brine Processing being established here in Kentucky.
am going to talk to EPA about this industry that treats the liquid waste from the oil & gas/tracking industries and
separates and concentrates the TENORM. Jeri Higginbotham have a contact we will be calling early next week to learn
more.
Thanks again,
George

ebject: Re: Water recycling and TENORM disposal
Good afternoon,
. s there anyway to find out who the landfill operator and facility was that approached Ryan Hall with a
Thanks
Rodney
Rodney Maze


Thanks Danny,
I've asked Lance Huffman in my office to coordinate any need for DOG involvement with the request
below because he handles a lot of the DOG issues. We will likely be interested in the list of UIC wells .
consultation?
GP925
1

2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
Please note thatany form Qf c::listrib1.1tiQO, copying, forwarding or use of this communication or the

Since primacy lies with EPA on inspecting these wells the point of contact for the regional contract
inspector is:
The contract UIC inspectors for EPA Region 4 in KY are/were Carl Weller and Red Fox. However,
- Carol Chen is/was a Groundwater Enforcement Specialist for EPA Region 4. Her number
is/was: 404-562-9415
Thanks
Dan Fraley

Sent: Friday, February 12, 2016 12: 11 PM
2
GP926
Danny,
Thank you,
Sarah

Kari,
email from Radiation Health Branch advising this company it is illegal to transport NORM/TENORM into
effects of TE NORM on the water. George Partridge in SWB has been working with him regarding
TENO RM sludges as well.
Thanks

2 Hudson Hollow
Frankfort, KY 40601
ph.(502} 564-2356 ext. 640
fx. (502} 564-9212
Daniel. Cleveland@ky.gov
product and covered by the attorney-client privilege. It is tor the exclusive use of the intended recipient(s).

Mr. Hall is asking if his company can inject "out-of-state oil and gas production fluid containing TENORM
GP927

-Hello Mr. Ha111
Yes, our Central Midwest Interstate Low-Level Waste Compact (http://www.cmcompact.org/ ) of which
KV is a member with IL, strictly prohibits the disposal of out-of-compact wastes in the Commonwealth of
contaminated wastes from WV, OH, PA or any other state should be disposed of here in KV. That would
include the disposal of sludge generated at your facility in KV from the processing of produced water
from WV oil and gas wells. That TE NORM contaminated wastes material should not be disposed of in
containing TENO RM in the company's disposal wells here in KV, I am going to have to defer to my
2
~h.all ?e the e;icclusive regulatory r~sponsibility of the stat~s, ~~ "~r}{t~~~r~~t~~.h,
~:~~fls;;~~l~,,,,":,~::~I~llltfi(~1~if~%;!~~;:,:: ~1
radioactivity of rocks or soils, or background radiation, but instead r~Ieis~q
tf
~I ~!~~?
.~.~~~\~~;gJ;'".]~shilmg~~11Y'I~li[~i!2~ij,J?y.l~R~RQlf#_\~fpJ;~mt~~

offense.
4
GP928
(https:Uapp.sos.ky.gov/ftsearch/ ). I believe all companies doing business in the Commonwealth of KY
contact me.
Regards,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<image001.jpg>
Sent: Wednesday, February 101 2016 2:02 PM

Hello Curt,
Best,
Ryan Hall
GP929
5
Technical Director

Mobile:(724} 289-7475
Office: 855-303-9416
37
- Grande Meadows Dr. Ste. 201
----------
GP930

.rom:
Sent:
To:
Subject:

Bevins, James (EEC)
RE: AI#l25200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Thank you for sharing this with me.

George

To: Maze, Rodney (EEC); Partridge, George (EEC)
FYI.

: Bevins, James (EEC)
bject: FW: AI#125200 - Advanced TENORM Services- Morgan Co - -Lab audit requested
ASarah/Frank: Thought you all might be interested since we have discussed this in the past. Good catch on James part
'Wduring the inspection.
James intends to discuss this with Eric Cole/Wells Group in the future, any suggestions on how we approach this?
Frank did the lab lose its certification on 01/01/15 or is James correct in saying 01/01/2016?
Thanks
Dan Fraley
.Sent: Friday, February 12, 2016 4:02 PM

Danny,
Thanks for the update. I was doing a KYG11 CEI at the Louisa Wells Group Ready Mix facility today (Al 2631) and
requested the most recent COC and analytical reports. They are attached. Apparently, the Wells Group is doing their
own pH and are field certified for this. However, Advanced Tenorm Services is their lab for TSS and O&G. The last
samples were collected prior to their certification expiring on Jan. 1, 2016 (per Frank Hall's e-mail below). The Louisa
Group hasn't collected samples for the 1st quarter 2016 yet. With that said, I intend to discuss this with Eric Cole
(""".Coordinator for Wells Group) and make sure his 1st quarter 2016 samples are analyzed by a certified lab another
that Advanced Tenorm Services. At present, we can't cite them for not complying with the WW lab certification
requirement. Do you see anything I'm missing here? Keep in mind that there are multiple Wells Group locations in our
region that this will apply to.
ms
GP931
Thanks,
James

To: Bevins, James (EEC)
From: Hall, Frank (EEC)

To: Fraley, Daniel (EEC); Gaddis, Sarah (EEC)
Sara/Dan,
We took a look at this after our conversation. Advanced TENO RM Services KV08061 is no longer certified as of January
1, 2015 for failure to renew.
The Laboratory Certification Section is going to request a data package to determine reproducibility. We will keep you in
the loop.
Frank Hall
Kentucky Laboratory Certification

Subject: AI#125200 - Advanced TENORM Services - Morgan Co - -Lab audit requested
Sara/Frank: As we discussed on the phone this morning. DWM has some significant issues with this facility regarding
waste disposal issues. These DWM issues are not relevant to DOW at this time. What is relevant to DOW rig~t now is
the lab certification that the facility has as interim. Attached are pictures that were taken by DWM on 02/04/16 during
their investigation. Advance TE NORM has been workihg on lab certification since early on in 2015. Information about
the certification application and parameters are detailed in the Al# 125200.
As you can see by the pictures that lab is located in the public library in West Liberty. Some lab equipment is visible in
the photos. The address of 32 Crestview Drive according to Google earth places you near the airport in West Liberty.
Frank: As we discussed, I will be than willing to accompany you on your inspection/audit of the facility. We have a
vehicle here in the Morehead office that we can use. Just work out the details on your end and we will get this done
ASAP.
If you all have any questions just let me know and I will get you all answers.
Thanks
Dan Fraley
From: Hall, Karen (EEC)

GP932
2

.rom:
Sent:
To:
Subject:

Curt;
Jeri Higginbotham that attended the meeting in your offices last week has a contact in EPA to discuss some of our
concerns with.
We will be talking to EPA together and I will share what we learn with you.
George

I definitely agree George. I think you hit the nail right on the head when you first mentioned that at our meeting. I
personally believe that is a call for the EEC hazardous waste and the US EPA. I thought your colleague was going to
check into that for us with her EPA contacts. john Richards is the only person at EPA that I have ever dealt with
regarding rad and she indicated that J.ohn only handles risk analysis for EPA.

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.chfs.ky .govI dph/ radioactive. htm
N:t!!I&~
fW.f.iJ~,.T~O'i'~.fl~.1:'fH

GP933
1

Curt;
If we can show that an industry that takes the waste produced from the O & G industry, etc. and processes it to
"spE;!C:iC!I w9ste", that \Af()Ul_d open the door for us to address our concerns from a multitude of regulatory
perspectives.
George

Hello George,
KRS 224.46-530 would indicate that
if we can prove
the processed was.te be. ing disposed of by ATS generated by
.
.
Fairmont Brine and Shalewater Solutions .and others no longer meets the EPA definition of "special wastes'' but is
Mailstop HS1C~A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
E-mail: curt.pendergrass@kv.gov
Website: http:ijwww.chfs.ky.gov/dph/radioactive.htm
GP934

-Dispose of un.._wanted sources http://www.crcpd.org/StateServices/SCATR.aspx
/(ftLfJJ~~m
f~tll:-\iJONHz...'lt.1H

Curt;
Cory Hoskins has two businesses incorporated out of his home, BES LLC and Advanced TENORM Services. He appears
awaste management company sees and 2) being the generator the landfill has the impression that they are receiving
9waste that was generated in-state and not regulated, so they feel comfortable accepting it.
Dr. Ling also should know the safety precautions one would should take w)1en handling or sampling this type of
waste.
I want to do all I can to support the work that you and your Section is doing to safely manage and regulate TENO RM.
ediation safety as well as the site visits he has conducted .
Geroge
(ieorge P. PartridiJe Jr.
GP935
3
-------

Frankfort, KY 40601
(502) 564-6716 ext. 4651

Regards,
Curt

sh~U ~e the e~~lusiv.e r~gulatoryresponsibility ()f the states, ~~()~pf~~~~D~~~R~J;SQ~
~~~F~'!f~f~~s~uffl~:!lil1'~~
'"'" , , ,~~,!-~pi~~J

4
GP936

e;ffense.
211.862 Definitions for KRS 211.861 to 211.869. http://www.lrc.ky.gov/statutes/statute.aspx?id=8501

fatl,ioactiyit}' ofroc~,~ .or s()il.~, ?r ~ackgr()und radiati()l1 but instea~refet~:t.d
~;~o/.~~s~f&~~~~~~~~!t:~faJt~~lM.~clhg~6411y~~n~~cech~Y:~~9ntJ;Ollalj1~~P~~etig~3

Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
.ebsite: http://www.chfs.ky.gov/dph/radioactive.htm
From~


-~:Cory Hoskins; Robert Brenna; Richard Yuen
bject: RE: New Comment from KLYSTAR.com
Hi George,
GP937
5
absence.
Leong
Dr. Leong Ying

KL YTEC - President
leong.ylng@kf\jteC::.com
Mobile: 212 203 5842

Hi Leon,
First
name:
Last
name:
George
Partridge
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
Comment:
Kind Regards
George Partridge

6
GP938
.rtridae, George (EEC)

.rom:
Sent:
To:
Subject:

FW: Vice President of Advanced TENORM Services
Jeri;
Look forward to calling EPA next week!
George

1defin. ite. ly agree George. I think you hit the nail right on. the head when you first mentioned that at our meeting. I
W'personally believe that is a call for the EEC hazardous waste and the US EPA. I thought your colleague was going to
check into that for us with her EPA contacts. John Richards is the only person at EPA that I have ever dealt with
regarding rad and she indicated that John only handles risk analysis for EPA.
Kentucky Radiation Health Bra.nch
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Website: http://www.ch.fs.ky.gov/dph/radioactive.htm
ent: Friday, February 12, 2016 4:48 PM

GP939
1
Curt;
If we can show that an industry that takes the waste produced from the 0 & G industry, etc. and processes it to
perspectives.

Thci_nk again for_all y()ua_re doing!_
George

Hello George,
KRS 224.46-530 would indicate that if we cah prove the processed waste being disposed of by ATS generated by
Fairmont Brine and Shalewater Solutions and others no longer meets the EPA definition Of "special wastes" but is
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564~1492
Ken -.
---"""
GP940
9,,,,,,, '

Curt;
Dr. Ling has used his reputation and skills to support the activities of Advanced TE NORM Services. It appears that
things for him: 1) TE NORM is not mentioned in the correspondence or the name of the company that the landfill or
evaste at a landfill where the workers are not using PPE or are trained on this type of waste .
waste.
Geroge
George P. Partrid"ge Jr.

~epartment
for Environmental Protection
W\' Division of Waste Management

.
,

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP941
3

Regards,
Curt
211.863 Control of commerce of low-level radioactive waste in and orit of Kentucky

-- Prohibitions -- Exemption.
http://www.Irc.ky.gov/statutes/statute~aspx?id=8502

shall be the exclusive re ulatory responsibilit
the
'~'~t~t11~
'~~''""'''
;~i~&~~.:

offense.

4
GP942
practices. Naturally occurring radioactive material does not include the. n~tural
r~~i~~St~~~~Y.~tIC>~~~ ()f..~.~.~~s ~.,~~. ~(l~~~E~~l1~ r.adiat~()~?~u!. inst~ad i~f~rsi(.), . . . ..

II1.~~erJ,&JiW.l:xP~.@~i:t<i10a.~t1y1ty1s.:J~cll110lgg19ally~l1hanced1:>y.~011tr9llaple.pr~ct1ces,
f~1Ji$i.aJ~~f:!iHm~Ii:J?i:~tt~~~);
. .
.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Pay your' fees on line at https:/lprd.chfs.ky.gov/rad epay/
rn~
..,.,...,..
:JJlfl:nrJN .


Hi George,
. n k you for connecting with me .... the profile you described do indeed match me perfectly ....
GP943
5
absence.
Leong
Dr. Leong Ying

KLYTEC - President
Mobile: 212 203 5842
From: george. pa rtridge@ky.gov [mailto:george. partridge@ky.gov]

Hi Leon,
First
George
name:
Last
Partridge
name:
Address:
City:
State:
Zipcode:
Country:
Tel:
502-564-6716 Ext 4651
Email:
Comment:
Kind Regards
George Partridge

Checked by A VG - www.avg.com
I
GP944
Partrid e, George (EEC)

.rom:
Maze, Rodney (EEC)

imageOOl.png
Sent:
To:
Subject:
Attachments:
We will gettogether and plan a trip to Big Run and Pressure Tech next week
Rodney Maze
Rodney;
Thank you for copying me on this. I see companies like Fairmont Brine Processing being established
here in Kentucky. I am going to talk to EPA about this industry that treats the liquid waste from the oil
& gas/tracking industries and separates and concentrates the TENORM. Jeri Higginbotham have a
contact we will be calling early next week to learn more.
!.
Thanks again,
George

Good afternoon,
Is there anyway to find out who the landfill operator and facility was that approached Ryan Hall
with a competitive bid for disposal.
Thanks
Rodney
Rodney Maze
I.
I

GP945
1
Thanks Danny,
I've asked Lance Huffman in my office to coordinate any need for DOG involvement with
the request below because he handles a lot of the DOG issues. We will likely be
interested in the list of UIC wells.
Would it be fair to refer the requesting company and CHFS - RHB to the contacts below
for further consultation?

Energy and Emtironrnent Cabinet
2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
Confidentiality Notice: This communication contains information which is confidential,
attorney work product and covered by the attorney-client privilege. It is for the exclusive
use of the intended recipient(s). Please note that any form of distribution, copying,
forwarding or use of this communication or the information therein is strictly prohibited
and may be unlawful. If you have received this communication in error please return it to
the sender and then delete the communication and destroy any copies.


Daniel: Here is the most updated information on the UIC contacts for the Morehead
Regional Office. These are very subject to change. If any of the numbers that were are
referencing you too are not good, please let us know and we will run down the
numbers. It might be good to contact the Division of Oil and Gas they might have
additional numbers and contacts to address any questions you may have as to the
disposal of RAD waste in UIC wells.
Since primacy lies with EPA on inspecting these wells the point of contact for the
regional contract inspector is:
The contract UIC inspectors for EPA Region 4 in KY are/were Carl Weller and Red
Fox. However, I never met these guys and don't have their phone numbers. I'd
say someone with DOG has them so let me know if we need them.
- Carol Chen is/was a Groundwater Enforcement Specialist for EPA Region 4. Her
number is/was: 404-562-9415
GP946
In addition my inspector gave me list of UIC wells for the Morehead Region in
case you are interested. You can filter to the active sites in the excel
spreadsheet.
Thanks
Dan Fraley

Danny,
Thank you,
Sarah

Kari,
As discussed, below is an email chain from the company wanting to utilize injection
wells in Kentucky to dispose of produced water/production fluids that have been, for
lack of a better word, separated from technologically enhanced naturally occurring
radioactive materials (TENORM). Also in this chain is the email from Radiation Health
Branch advising this company it is illegal to transport NORM/TENORM into Kentucky
from any state except Illinois and referring the injection well question to HWB and
SWB.
My understanding is that EPA has primacy over injection wells, but I don't know who
that contact may be. Also, I know DOW regulates production fluids/brine, so I think this
may be a CTAB question as well.
Curt Pendergrass at CHFS may be able to answer any questions about the proposed
disposal and the effects of TENO RM on the water. George Partridge in SWB has been
working with him regarding TENORM sludges as well.
Thanks

2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
GP947
3

Sent: Friday, February 121 2016 11:22 AM

Mr. Hall is asking if his company can inject "out-of-state oil and gas production fluid
containing TENO RM in the company's disposal wells here in KY." Curt, in Public Health,
is deferring to his colleagues in the solid and hazardous waste divisions of the Energy
and Environment Cabinet. It sounds like a question for you or Kevin. Also, Curt couldn't
find his company registered on the SOS website.

Cc: McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge,
George (EEC); Fowler, Kathy L (CHFS PH); Frame, Jason R (Jason.R.Frame@wv.gov)
Hello Mr. Hall,

Yes, our Central Midwest Interstate Low-Level Waste Compact
(http://www.cmcompact.org/) of which KY is a member with IL, strictly prohibits the
disposal of out-of-compact wastes in the Commonwealth of Kentucky. That includes EPA
defined "special wastes" containing technologically enhanced naturally occurring
radioactive materials generated from the oil and gas exploration and production fluids
and brines from out-of-compact operations. This office interprets "the region" in KRS
211.863 to mean strictly the Commonwealth of Kentucky and the State of Illinois. No
out-of-compact generated TENORM contaminated wastes from WV, OH, PA or any
other state should be disposed of here in KY. That would include the disposal of sludge
generated at your facility in KY from the processing of produced water from WV oil and
gas wells. That TENO RM contaminated wastes material should not be disposed of in
landfills in the Commonwealth of Kentucky. As for injecting that out-of-state oil and gas
production fluid containing TENO RM in the company's disposal wells here in KY, I atn
going to have to defer to my colleagues in the solid and hazardous waste divisions of the
Energy and Environment Cabinet whom I am including on this e-mail. But having said all
of that, I would love to see your company's "radiation health plans and laboratory data".
KRS 211.863 Control of commerce of low-level radioactive waste in and out

of Kentucky
-- Prohibitions -- Exemption.
(3) Naturally-occurring radioactive material (NORM) as defined in KRS
211.862(8)
shall be the exclusive regulatory responsibility of the states, ~~~~pf:i.li~UnB};R~['~'gg
4
GP948
'
KRS 211.862 Definitions for KRS 211.861to211.869.

(8) "Naturally-occurring radioactive material" (NORM) means naturally
occurring
materials not regulated under the Atomic Energy Act of 1954, as amended,
whose
practices. Naturally occurring radioactive matefial does not include the natural
r~dioactiv~tyouo~ks ?rsoils, or back~o.un? r,adiation, ~ut inste~d t~~~.fs1
liC::~==:~i-i{eOW~IoJiii>;i\IY tliJlj]jc:<>d,b}"x~nlti;Il~~l~

(1) Any person who fails to comply with any provision of KRS 211.859 or
211.863, or
211.859 or KRS 211.863 and 211.865 shall be assessed a civil penalty not less
than
($100,000). Each day of the violation or noncompliance shall constitute a
separate
offense.
One other comment. You said that Shalewater operates a business here in the
Commonwealth of Kentucky. However, I could find no registration of the company on
the KY Secretary of State's website (https:Uapp.sos.ky.gov/ftsearch/ ). I believe all
companies doing business in the Commonwealth of KY are required by law to register
with the Secretary of State's office and obtain the required permits necessary to
operate (http:Uonestop.ky.gov/operate/Pages/permits.aspx ).
If you have any additional questions or comments concerning this matter, please do not
hesitate to contact me.
Regards,
Kentucky Radiation Health Branch.
Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Be notified of proposed regulation changes https:/fsecure.kentucky.gov/Regwatch/
5
GP949

<imageOOl.jpg>
'9

Hello Curt,
We hadbeen approachedby a landfill operator and they gaveus a competitive bid
for disposal. We were then notified that 211.863 prohibits disposal of NORM
from outside of the "region". I am reaching out to you today because we have
existing operations near Kentucky, and may be siting future locations within your
boarders.
,~:,;~fr"
:to H~
~a.tf:w~n
dfW~f~ii
"t." ".!c':-'.J,5"c~{~".{~;;'l"'!6~
We would be more than happy to share our radiation health plans and laboratory
data with you.
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image001.png>
GP950
'

Maze, Rodney (EEC)
.rom:
Sent:
To:
Subject:
Rodney;
Look forward to our site visits!
Thanks again for being so generous with your time and listening to my concerns!
I have felt over-whelmed knowing that the health and future well-being of operators and all those associated with the
transport and disposal activities related to the shipment of the Fairmont Brine ~recessing Waste have been
j.eopardized. I also worry about those associated with the school across the street from Blue Ridge Landfill as well from
the windblown dust and the tracking of dust/sludge particles, etc. associated with traffic to and from the landfill.
I totally agree with Curt Pendergrass's email correspondence with Jason that I have copied and pasted below (if you
have not already seen it) .
so felt that someone representing hazardous waste should have been at the meeting today. Since hazardous waste
. . nagement is my background, I will be pursuing our questions and concerns myself with EPA.
, .hanks again!
George
From: Pendergrass, Curt (CHFS DPH) [niailto:Curt.Pendergrass@ky.gov]

To: Frame, Jason R
thanks especially for the follow-up telephone call on wha.thas transpi~edbetween yo~r o-ffk~and Fai.~~?nt Brine
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J>le;in~ .. ook~ We will be meeting next week with our colleagues in the Division of Waste Management to decide
w<rn~-'<c,,\'._'.,.;'_,;,_:,,,,,;/,",_-,
GP951
1
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Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
Dispose of unwanted sources http://www.crcpd.org/StateServices/SCATR,aspx
.-..
8'
GP952
1,:
1:

Ryan Hall <rhall@shalewater.com>
.rom:
Sent:
To:
Cc:
Subject:
Thank you again for the clarification. Oil and gas development has thrust the issue of TEN ORM waste
management into the forefront and the current economic climate has dictated that companies seek the most cost
effective options.
Most folks are using PA for low level TENORM solutions and US Ecology, Austin Masters or Energy
Solutions for disposal outlets for higher level wastes.
Best.
Sent from my iPhone
On Feb 12, 2016, at 4:24 PM, Pendergrass, Curt (CHFS DPH) <Curt.Pendergrass@ky.gov> wrote:
Your welcome Mr. Hall. I am sure my colleagues in EEC can answer all your questions regarding disposal
wells. Also, my Division Director reminded me of the fact that our Kentucky Regulatory Statute KRS
211.862 Definitions for KRS 211.861 to 211.869. (http:Uwww.lrc.ky.gov/statutes/statute.aspx?id=8501)
defines "region" as follows:
(10) "Region" means the geographical area ofthe state of Illinois and the Commonwealth of
Kentucky;
Therefore your question regarding what is meant by the term "outside the region" in KRS 211,863
"Control of commerce of low-level radioactive waste in and out of Kentucky-- Prohibitions Exemption" (http://www.lrc.ky.gov/statutes/statute.aspx?id==8501) would be any state other than KY or
IL.
(3) Naturally-occurring radioactive material {NORM) as defined in KRS 211.862(8)
shall import naturally occurring radioactive material (NORM) from Piltgi~~,tH~
;r~'gT6l'l'. for disposal in Kentucky, or dispose of such imported material,ln, K~~tucky,
Regards,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
GP953
1
Fax:502-564-1492
Dispose of unwanted sources http:lfwww.crcpd.org/StateServices/SCATR.aspx
<image001.jpg>

F~IJr1.1ary 12, 2016 11:57 AM
Cc: Chance Richie; McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge,
George (EEC); Fowler, Kathy L (CHFS PH); Jason R Frame
___ Sent: Frlciciy,
Hello Curt,
Thank you for the prompt and informative response. To be clear, I stated in the original email
that we have existing locations near Kentucky and may at some point in the future wish to locate
within the state. We do not have anything there at the present (nor have had anything in the
past). The line of questioning was related to future opportunities. I will follow up with
the Energy and Environment Cabinet concerning the disposal well question.
Thanks again,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
On Feb 12, 2016, at 10:20 AM, Pendergrass, Curt (CHFS DPH)

<Curt.Pendergrass@ky.gov> wrote:
Hello Mr. Hall,
2
GP954
'
and brines from out-of-compact operations. This office interprets "the region" in KRS
out-of-compact generated TENO RM contaminated wastes from WV, OH, PA or any
other state should be disposed of here in KY, That would include the disposal of sludge
production fluid containing TE NORM in the company's disposal wells here in KY, I am

of Kentucky
-- Prohibitions -Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id=8502
211.862(8)
ll!:!~?!f~::~!!!~!!!!:!~!!!~I:
occurring
whose
radionuclide concentrations have been increased by or as a result of human '
radioactiviW :frocks :r so.ils~ or b~ckgr:und radiation, ~utinst~a~ r~t~J.~~i~
:.::H~[~Ii~@]f~~ti~1iY~~~'.[~11!i~j~gi~~ni:~Ii!lali9e,a;~Y~SdA~fo~!!~lJ,}~
r~A~t!ln{lili!lf~nfni~~rlf~)si

211.863, or
than
separate
offense .
the KY Secretary of State's website {https://app.sos.ky.gov/ftsearch/ ). I believe all
3
GP955

operate (http:Uonestop.ky.gov/operate/Pages/permits.aspx ).
Regards,
Mailstop HSlCcA
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
<imageOOl.jpg>

Hello Curt,
We had been approached by a landfill operator and they gave us a competitive bid
boarders.
I have several questions as it relates to that. Do you interpret "region" to be
different than "state"? Along those same lines, if I am operating a disposal well
in eastern Kentucky it is very probable that I am receiving some produced water
from WV wells. I generally put all of my water through a pretreatment
step. Pretreatment generates a sludge that will have some TENORM signature
and part of this will have been from out of state sources. Would this rule also
prohibit me from accepting out of state produced water for underground injection
in KY?
data with you.
Best,
Ryan Hall
Technical Director
4
GP956

Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
<KRS 211.863 CMC statute.pdf>
GP957
5
&tridge, George (EEC)

.rom:
Sent:
To:
Subject:
Attachments:
Tracking:

Maze, Rodney (EEC)
FW: TENORM Notice to Solid & Special Waste Facilities
TENORM Notice to Solid & Special Facilities 021616.docx
Recipient
Delivery
Read
Maze, Rodney (EEC)
Delivered: 2/12/2016 7:27 PM
Read: 2/12/2016 8:09 PM
Rodney;
I did not see this letter for the first time until a few minutes ago. I wish that you and I could have been included in its
drafting and review.
Waste generators of TENO RM claim the RCRA exemption 40 CFR 261.4(b)(5) [which Cory Hoskins used] which reads as
follows:
Title 40: Protecfon Of Environment
RT 261_,;IDENTlflCATION AND LISTING OF HAZARDOUS WASTE
bpart A-General
261.4 Exclusions.
(b) Smid wastes which are not hazardous \>\i'astes_ The folloi.ving solfdi wastes are not hazardous wastes:
(5) Drilling fluids, produced waters, and other wastes associated with the exploration, development, or production of
crude oil, natural gas or geothem1al energy_
I anticipate all fracking and exploration related oil and gas associated waste will have the words or abbreviations such as
"O & G" in the name or description of the waste so the disposal firm will consider it a special waste and exempt from
hazardous waste regulations.
In the attached letter, the oil and gas/fracking industry is not even mentioned which is the primary source we are
concerned about. I also think the letter could have been more descriptive how the TE NORM is concentrated and the
products that it may appear in. Materials associated with O & G waste include:
Soils
Sludges
Tank bottoms
Filter Socks
I question how useful this letter is going to be as an educational tool or notice to landfill facilities.
19it
to encourage you and others in our field offices to contribute what they observe in manifests, etc. to what needs
to be shared and distributed .
Should this be brought up with Jon Maybriar Monday? Just a thought.
GP958
1
This is something that I was not part of or ask to participate or even shared with me until now and I want to respect the
work of others.
Look forward to our meeting on Monday!

George
-From: Earlton, John (EEC)

(EEC)
Hello ALL,
Please find attached the notice to all solid and special waste facilities concerning TENO RM. I made all of Jon Maybriar's
Thanks!
flolut~. ~
Ene~gy and Environment Cabinet
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049
GP959
~
6 think before you Ink
GP960
3
From:
To:
Sent:
Subject:
Microsoft Outlook
Maze, Rodney (EEC)
Delivered: FW: TENORM Notice to Solid & Special Waste Facilities

Maze. Rodney (EEC) (Rodney.Maze@ky.gov)
Subject: FW: TENORM Notice to Solid & Special Waste Facilities
GP961
1

.rom:
Sent:
To:
Cc:
Subject:

'Ryan Hall'
Maze, Rodney (EEC)
Ryan;
This email correspondence will be helpful to us.
Thank you for copying me.
George
(jeorge P. Partridge Jr., Pfi'D, P.'E., Q..'EP

nkfort, KY 40601
(502) 564-6716 ext. 4651
From: Ryan Hall [rnailto:rhall@shalewater.com]

Thank you again for the clarification. Oil and gas development has thrust the issue of TENORM waste
management into the forefront and the current economic climate has dictated that companies seek the most cost
effective options.
Ifll~f~\l~~J~f~tai~ti\8~!iilb1t~w;;m~~s-~~tr ifiY;:~jjj "Miii~r~:~rtr!i~Ir~

1
119
.est.
Sent from my iPhone
GP962
1
On Feb 12, 2016, at 4:24 PM, Pendergrass, Curt (CHFS DPH) <Curt.Pendergrass@ky.gov> wrote:
Your welcome Mr. Hall. I am sure my colleagues in EEC can answer all your questions regarding disposal
wells. Also, my Division Director reminded me of the fact that our Kentucky Regulatory Statute KRS
211.862 Definitions for KRS 211.861 to 211.869. (http://www.lrc.ky.gov/statutes/statute.aspx?id=8501)
defines "region" as follows:
(10) "Region" means the geographical area of the state of Illinois and the Commonwealth of
Kentu_~~YL __
Therefore your question regarding what is meant by the term "outside the region" in KRS 211.863
"Control of commerce of low-level radioactive waste in and out of Kentucky-- Prohibitions Exemption" (http://www.lrc.ky.gov/statutes/statute.aspx?id=8501) would be any state other than KY or
IL.
shall import naturally occurring radioactive material (NORM) from 291~~~tF~
f~gf@' for disposal in Kentucky, or dispose of such imported material in Kentucky,
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
<imageOOl.jpg>

Cc: Chance Richie; McKinley, Matthew W (CHS-PH); Keffer, Christopher (CHFS Rad Hlth); Partridge,
George (EEC); Fowler, Kathy L (CHFS PH); Jason R Frame
Hello Curt,
Thank you for the prompt and informative response. To be clear, I stated in the original email
that we have existing locations near Kentucky and may at some point in the future wish to locate
within the state. We do not have anything there at the present (nor have had anything in the
GP963
past). The line of questioning was related to future opportunities. I will follow up with
the Energy and Environment Cabinet concerning the disposal well question .
Thanks again,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
On Feb 12, 2016, at 10:20 AM, Pendergrass, Curt (CHFS DPH)

<Curt.Pendergrass@ky.gov> wrote:
Hello Mr. Hall,
and brines from out-of-compact operations. This office interprets "the region'' in KRS
out-of-compact generated TENO RM contaminated wastes from WV, OH, PA or any
other state should be disposed of here in KY. That would include the disposal of sludge
production fluid containing TENORM in the company's disposal wells here in KY, I am

of Kentucky
-- Prohibitions -Exemption. http://www.lrc.ky.gov/statutes/statute.aspx?id=8502
211.862(8)
3
GP964

211.869. http://www.Irc.ky.gov/statutes/statute.aspx?id=8501
occurring
whose
practices. Naturally occurring radioactive material does not include tiie natural
radioactivi~yp~ro~Ks or soils, ?rbac~ground radiati?n, 1Jutinst~ad~~f~rs fg
1mtc~==~:::~~!o~UQl\iiiiitlI{e~ii'!l)C,;d bY.2i:!liirOJI@!~

211.863, or
than
separate
offense.
the KY Secretary of State's website (https://app.sos.ky.gov/ftsearch/ ). I believe all
operate (http://onestop.ky.gov/operate/Pages/permits.aspx ).
Regards,
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
4
GP965

<image001.jpg>
To:

Hello Curt,
We had been approached by a landfill operator and they gave us a competitive bid
boarders.
I have several questions as it relates to that. Do you interpret "region" to be
different than "state"? Along those same lines, if I am operating a disposal well
in eastern Kentucky it is very probable that I am receiving some produced water
from WV wells. I generally put all of my water through a pretreatment
step. Pretreatment generates a sludge that will have some TENORM signature
and part of this will have been from out of state sources. Would this rule also
prohibit me from accepting out of state produced water for underground injection
in KY?
data with you.
Best,
Ryan Hall
Technical Director
Mobile:(724) 289-7475
Office: 855-303-9416
<image002.png>
<KRS 211.863 CMC statute.pdf>
GP966
5

.From:
To:
Sent:
Subject:
Maze, Rodney (EEC)

Read: FW: TENORM Notice to Solid & Special Waste Facilities
Your message
Subject: FW: TENORM Notice to Solid & Special Waste Facilities
Sent: Friday, February 12, 2016 7:26:29 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Friday, February 12, 2016 8:08:35 PM (UTC-05:00) Eastern Time (US & Canada) .
GP967
1
&ridge, George (EEC)

Maze, Rodney (EEC)
Re: TENORM Notice to Solid & Special Waste Facilities
image002.png; image004.png; image003.png
.rom:
Sent:
To:
Subject:
Attachments:
George,
I believe our opportunity to explain in depth with more details will come when we have the regional office meeting with
the facility managers. I plan on having a rep from the Rad Branch and yourself at our meeting. I can't answer for the
other regional offices.
Rodney Maze
Rodney;
I did not see this letter for the first time until a few minutes ago. I wish that you and I could have been
included in its drafting and review.
Waste generators of TE NORM claim the RCRA exemption 40 CFR 261.4(b}{S) [which Cory Hoskins used]
which reads as follows:
Title 40: Protecfon of Environment
PAJRT 261-ID.ENTlFlCATION AND USTING OF HAZARDOUS WAST!E
Su!Jpart A-General
26,1.4 Exclusions.
(b) Solid wastes which are not hazardous 1..v:astes. The foBov..ing solid wastes are not hazardous wastes:
(5) Drii!ing fluids, produced waters, and other wastes associated with the exploration, development, or procluctic
crude oil, nawral gas or geothermal energy.
I anticipate all tracking and exploration related oil and gas associated waste will have the words or
abbreviations such as "O & G" in the name or description of the waste so the disposal firm will consider
it a special waste and exempt from hazardous waste regulations.
In the attached letter, the oil and gas/tracking industry is not even mentioned which is the primary
source we are concerned about. I also think the letter could have been more descriptive how the
TENORM is concentrated and the products that it may appear in. Materials associated with 0 & G waste
include:
Soils
Sludges
Tank bottoms
Filter Socks
GP968
1
I want to encourage you and others in our field offices to contribute what they observe in manifests, etc .
to what needs to be shared and distributed.
This is something that I was not part of or ask to participate or even shared with me until now and I
want to respect the work of others.
Lookforward to our meeting-on IVlonday!
George

Cc: Aldridge, Louanna (EEC); Partridge, George (EEC); Green, Robin C (EEC); Aldridge, Tabitha (EEC);
Hello ALL,
Please find attached the noti.ce to all solid and special waste facilities concerning TENORM. I made all of
Jon Maybriar's changes and also changed the heading as well to reflect the fact that we opened the
scope of the notice to include more than just solid and special waste landfills. The heading now reads
"NOTICE TO ALL SOLID AND SPECIAL WASTE FACILITY OWNERS AND OPERATORS".
Finally, the Notice is dated for Tuesday, February 16th in order to accommodate Daniel's 24-hour
courtesy to inform CHFS of this notice.
Thanks!
fo*~, ~
GP969
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049

<TENORMNotice to Solid & Special Facilities 021616.docx>
GP970
3

Maze, Rodney (EEC)
.rom:
Sent:
To:
Subject:
Rodney;
Sounds good!
Thank you again for all you are doing. I look forward to us working together.
George
Subject: Re: TENORM Notice to Solid & Special Waste Facilities
rge,
lieve our opportunity to explain in depth with more details will come when we have the regional office meeting with
the facility managers. I plan on having a rep from the Rad Branch and yourself at our meeting. I can't answer for the
other regional offices .
Rodney Maze
Rodney;
I did not see this letter for the first time until a few minutes ago. I wish that you and I could have been
included in its drafting and review.
Waste generators of TE NORM claim the RCRA exemption 40 CFR 261.4(b)(5) [which Cory Hoskins used]
which reads as follows:
Title 40: Protection of Environment
PART 261-IDENTIFICATION AND USTING OF HAZARDOUS WASTE
Subpart A-General
261.4 Exclusions.
(b) Solid wastes which are not hazardous 'WaStes_ The following solid wastes are not hazardous wastes:
(5) Drilling fluids, produced waters, and other wastes associated with the exploration, development, or produc:tic
crude oil, natural gas or geothermal energy.
GP971
1
I anticipate all fracking and exploration related oil and gas associated waste will have the words or
abbreviations such as "O & G" in the name or description of the waste so the disposal firm will consider
it a special waste and exempt from hazardous waste regulations.
In the attached letter, the oil and gas/fracking industry is not even mentioned which is the primary
source we are concerned about. I also think the letter could have been more descriptive how the
TENO RM is concentrated and the products that it may appear in. Materials associated with 0 & G waste
include:
_$_oils
Sludges
Tank bottoms
Filter Socks
I want to encourage you and others in our field offices to contribute what they observe in manifests, etc.
to what needs to be shared and distributed.
This is something that I was not part of or ask to participate or even shared with me until now and I
want to respect the work of others.
Look forward to our meeting on Monday!

George

Cc: Aldridge, Louanna (EEC); Partridge, George (EEC); Green, Robin C (EEC); Aldridge, Tabitha (EEC);
Hello ALL,
Please find attached the notice to all solid and special waste facilities concerning TENORM. I made all of
Jon Maybriar's changes and also changed the heading as well to reflect the fact that we opened the
scope of the notice to include more than just solid and special waste landfills. The heading now reads
"NOTICE TO ALL SOLID AND SPECIAL WASTE FACILITY OWNERS AND OPERATORS".
Finally, the Notice is dated for Tuesday, February 15th in order to accommodate Daniel's 24-hour
courtesy to inform CHFS of this notice.

Thanks!
GP972
2
~~.~
Internal Policy Analyst IT
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049
<TENORM Notice to Solid & Special Facilities 021616.docx>
GP973
3
lrtridge, George (EEC)
'.rom:
Weems, George (EEC)

RE: TENORM - technically enhanced naturally occurring radioactive material
Sent:
To:
Subject:
Excellent! I thought about downloading the whole site but only after he took it down. I was a bit slow on that. Should
have thought of it when I found that photo.

Subject: RE: TENORM - technically enhanced naturally occurring radioactive material
George;
I printed out the pages of the website and scanned them.
They are attached.
9ankyou,
George
..
....,,,.,.,,,,.,,,,,,,,,.
,,,,,,,,,,,,,,,,,,,,,,,,,,.,,, ,,.,.,,,,,,,,.,

Subject: FW: TENORM - technically enhanced naturally occurring radioactive material
George, did you perchance download Cory's Website? If not, this may be the only evidence you have on their
About Our Company

, ironmental services, a company providing environmental remediation, transportation, disposal, laboratory
consulting services to general industry, municipalities, and military and government entities .
http://advtenorm.com/about/
GP974
GP975
2

.rom:
Sent:
To:
Subject:
Carlton, John (EEC)

George,
I appreciate your offered verbiage. But at this time, I believe from my conversation with Daniel, we were not willing to
classify this material quite yet except to say that it is radioactive and therefore is regulated by CHFS and that for a facility
to have accepted it may be a violation of their permit. Whether or not it meets CHFS's qualifications for regulation is up to
the disposal facility to figure out in the interim. We are just putting the facilities on notice that we are paying attention
and directing them to the appropriate statutes, regulations, and contact persons. Saying much more than that may
pigeon-hole us in the future and we would not want that.
Thanks again!
John

nt: Friday, February 12, 2016
5:45 PM
Carlton, John (EEC)
bject: RE: TENORM Notice to Solid & Special Waste Facilities
.ohn;
I appreciate all that you and Louanna are doing to address our concerns regarding TENO RM disposal at our landfills, etc.
abbreviation for the oil and gas or oil and gas exploration waste industry included.
Have a nice day!
George

Sent: Friday, February 12, 2016 4:46
PM
(EEC)
9ject: TENORM Notice to Solid & Special Waste Facilities
.Hello ALL,
Please find attached the notice to all solid and special waste facilities concerning TENORM. I made all of Jon Maybriar's
GP976
Thanks!
flolwt~. ~
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049
'L
6
think before you ink

GP977
2

.rom:
Sent:
To:
Subject:

Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth)
FW: Waste Management at TENORM
Looks like Waste Management is in the oil and gas exploration and production fluid waste business as
well as in the NORM disposal business (see https://www.wmsolutions.com/solutions/oil-gas/ and
below). They bought a company with a fracking fluid processing technology back in 2011
(http://www.oilandgasawards.com/sponsor/shalewater-solutions/) and the man who invented that
process went on to found Shalewater Solutions who recently contacted me about possible TENORM
disposal in KY. Below is a link to the closest WM facility that I could find that processes E&P and
NORM in OH. But now I can see why Fairmont Brine reached out to WM when it first tried to find a
home for its TENORM wastes. My guess is WM does it right and gave FBP a price quotation that
reflected proper disposition and FBP didn't like the number, hence the contract with ATS.
~rt Pendergrass, Ph.D.

-ervisor, Radioactive Materials Section
Af"'lailstop HS1C-A
9=rankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.

Subject: wm
tama County Landfill

Management Facility (Disposal)
GP978
1
497 Roush Hollow Rd.

Bidwell, OH 45614
Details
Map
New Search
Acceptable Materials
Non-Hazardous-
Auto Shredder Fluff

Biosolids
Construction & Demolition Debris
Drum Management-Solids
E&P Wastes
Industrial & Special Waste
Municipal Solid Waste
NORM (Naturally Occurring Radioactive Material)
https://www.wmsolutions.com/locations/details/id/15
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein.
GP979
2

.rom:
Sent:
To:
Subject:

Carlton, John (EEC)
John;
Thank you for helping me understand how this needs to be approached.
I appreciate all that you and the others are doing to address TENO RM and waste that is derived from it as well.
Please do not hesitate to contact me anytime I can support this effort. The last several weeks have been so intense
with all the emails, phone calls, and follow-up I have been doing after the reports we received of waste being shipped
from Ohio and West Virginia into Kentucky.
Hope this week goes for you,
9orge
at..rom:
Carlton, John (EEC)
~ent: Monday, February 15, 2016 8:22 AM

Subject: RE: TENORM Notice to Solid & Special Waste Facilities
George,
I appreciate your offered verbiage. But at this time, I believe from my conversation with Daniel, we were not willing to
classify this material quite yet except to say that it is radioactive and therefore is regulated by CHFS and that for a facility
to have accepted it may be a violation of their permit. Whether or not it meets CHFS's qualifications for regulation is up to
the disposal facility to figure out in the interim. We are just putting the facilities on notice that we are paying attention
and directing them to the appropriate statutes, regulations, and contact persons. Saying much more than that may
pigeon-hole us in the future and we would not want that.
Thanks again!
John

To: Carlton, John (EEC)
Subject: RE: TENORM Notice to Solid & Special Waste Facilities
.I
appreciate all that you and Louanna are doing to address our concerns regarding TE NORM disposal at our landfills, etc.
GP980
abbreviation for the oil and gas or oil and gas exploration waste industry included.
Have a nice day!
George

(EEC)
Hello ALL,
Please find attached the notice to all solid and special waste facilities concerning TENORM. I made all of Jon Maybriar's
Thanks!
~~,~
john.carlton@ky.gov
phone: 502.564.6716 ext. 4023
fax: 502.564.4049
GP981
2
think before you Ink

GP982
3
.tridge, George {EEC)

.rom:
Sent:
To:
Subject:
Weems, George (EEC)

Manifests
Hey George,
When did you originally request them?
GP983
1
-rtridge, George (EEC)

.From:
Sent:
To:
Subject:

Weems, George (EEC)
RE: Manifests
George;
The morning of our visit to Blue Ridge when we first met with Billy. I asked him to search for the list of companies I
presented him and provide all the manifests for Fairmont Brine. When I learned that additional companies were
sending wastes to Blue Ridge, on Friday morning I again requested manifests and extended my request to include all
waste received so we could identify all companies sending TENO RM waste to Blue Ridge. On Friday I wanted copies of
all the manifests for 2015 and January 2016.
George

.bject: Manifests
Hey George,
ewhen
did you originally request them?
GP984

.From:
Sent:
To:
Subject:
Attachments:
Maze, Rodney (EEC)

Maybriar, Jon (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems, George
Green Valley Landfill Inspection Report 02-04-16
DWMCEI020416.pdf
Jon,
Attached is a copy of the Green Valley Landfill inspection report. Please review and if everything looks OK I will lock it
and start on the NOV.
Thanks,
Rodney
GP985
Activity:

Kentucky Department for Environmental Protection
CIN20160002 Inspection
Lead Investigator:
Maze, Rodney
Agency Interest/Permit ID: 1592

Agency Interest Name:
Green Valley Landfill General Partnership
Agency Interest Address:
Type of Agency Interest:
Agency Interest Contact:
1551 Green Valley Dr

Ashland, KY 41102
WASTE- Solid Waste Landfill (562212)
Title:
Program: Solid Waste

County: Greenup
Phone:
Purpose: Inspection
Inspection Type: SW CEI Landfill, Contained
Inspection Date: 02/04/2016
Start Time: 01:20 PM
Latitude:
Longitude:
38.39765000
End Time: 04:30 PM
-82.80656000
Coordinate Collection Method:Decimal Degrees

Incident ID(s):
eral Comments:
nannounced site visit was conducted to address allegations that NORM/TEN ORM waste from outside the state of Kentucky
was accepted and disposed of at Green Valley Landfill. A request for waste documentation was provided for review during this
visit. After review of the waste documentation it was determined that NORM/TEN ORM waste was accepted and disposed of from
the state of Ohio at various dates from May 2015 through January 2016.
erson(s) Interviewed:
Name
Organization
Isee attached sign in sheet
AI Name:
GP986
Green Valley Landfill Genen
Activity:
CIN20160002
Page 1 of2
Status/Comments:
AI001592
Requirement
Results or Comments
Status
This facility accepted and disposed of an

unpermitted waste as per the Central Midwest
Interstate Low-Level Radioactive Waste Compact.
Has a permanent record of the source, disposal location and

quantity of any spill residues and limited quantity generator waste
been compiled?. [401KAR47:190 Section 8(5)]
This facility failed to compile a permanent record of

the source, disposal location and quantity of any
spill residues and limited quantity generator waste
as per 401KAR47:190 Section 8(5)
Is the owner or operator recording, on a form approved by the

cabinet, the daily cell locations, and dates of cover applications at
the landfill including: daily usage area, daily, interim, long term and
final cap installation dates and certification reports?. [401 KAR
48:090 Section 3(5)]
The owner or operator failed to record, on a form

approved by the cabinet, the daily cell locations, and
dates of cover applications at the landfill including:
daily usage area, daily, interim, long term and final
cap installation dates and certification reports as per
401 KAR 48:090 Section 3(5).
Is the site operated and maintained to provide compliance with the

permit?. [401KAR47:120 Section 1(1)]
----
Investigator:
Date:
Title:
ON - N-NotApplicable
DE - E-Not Evaluated
[Kl V - V-Out of Compliance-NOV
DC - C-No Violations observed
DI - I-No Violations obs-but impending viol trends obs
DD - D-Out of Compliance-Violations Documented
D 0 - 0-0ut of Comp-LOW non-recurrent Adm. or O&M
Received By:
Title:
Date:
Delivery Method:
AI Name:
Green Valley Landfill Genen
Activity:
CIN20160002
Page 2 of2
GP987
.From:
Sent:
To:
Subject:
Maze, Rodney (EEC)

Maybriar, Jon (EEC); Partridge, George (EEC); Hall, Karen (EEC)
RE: Green Valley Landfill Inspection Report 02-04-16
I was reviewing the Green Valley Landfill permit issuance sheet and I know why (or one reason} the Fairmont WV waste
went to Advanced Disposal Blue Ridge Landfill. Marion County WV isn't an approved source/county for the landfill.
Rodney
From: Maze, Roqney (EEC)

To: Maybriar, Jon (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems, George (EEC); Hall, Karen (EEC)
Subject: Green Valley Landfill Inspection Report 02-04-16

Jon,
Thanks,
.dney
GP988
.From:
Sent:
To:
Subject:
Maybriar, Jon (EEC)

Maze, Rodney (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems, George
Looks ok. I will forward to Daniel Cleveland for review

Jon,
Attached is a copy ofthe Green Valley Landfill inspection report. Please review and if everything looks OK I will lock it
Thanks,
Rodney
GP989
.From:
Sent:
To:
Subject:
Weems, George (EEC)

RE: Manifests
Ok, I'll put that in and the Friday request I emailed. I imagine he's trying to get his upper managernent on this too so
they can see how to respond to this. It wouldn't be smart to try to withhold the info. So I guess our NOV is going to be
1 quit accepting NORM of any sort
2 Do a comprehensive site survey
3 Send the requested manifests

Subject: RE: Manifests
George;
.'1Jiir.e morning of our visit to Blue Ridge when we first met with Billy. I asked him to search for the list of companies I
sented him and provide all the manifests for Fairmont Brine. When I learned that additional companies were
. a l l the manifests for 2015 and January 2016.
George

Subject: Manifests
Hey George,
GP990
!rtrid!!e George (EEC)

.rom:
Sent:
To:
Subject:
A survey of radiation levels at the site, extending to the property boundaries, taking into account the radiative
constituents present in the waste shipments received by the landfill. to assess the exteAt of coAtamiAatioA
(area) iAcludiAg all property owAed by the laAdfill.
An assessment of naturally-occurring background radiation levels coAtributed by shale at the site. Background
radiation levels shall be determined in onsite areas proven to be unaffected by waste constituents, or offsite at
an approved location that is geologically similar to the landfill. This ca A poteAtially be assessed by surveying for
radiatioA levels beyoAd the zoAe of coAtamiAatioA aAd coAsieleriAg the geography of the site. The goal is to
distiAguish betweeA radiatioA levels coAtributed by the waste aAd bacl(grouAd levels.
An evaluation of all potential exposure pathways ffitlte5 of the radioactive waste material to human and
environmental receptors both at the landfill and off-site. This evaluation shall consider the manner in which
baseel OA how the waste was received and managed by the landfill.
e.

RE: RE: Assessment of TE NORM Contamination at Blue Ridge
A detailed radiatioA survey that assesses the present radioactive hazard and associated risk to aAy poteAtial risk
preseAtly to landfill personnel operators aAd maAagemeAt activities at the site .
AAalysis of shale samples at the site to ideAtify aAy uAique characteristics that differ from the waste coAtaiAiAg
shale residue from Ohio aAd 1.Nest VirgiAia areas. (The New Albany Shale varies in radioactivity based on its
lithology. We have to be really careful here.)~
Assessment of contaminated runoff (stormwater, etc.) from the site along with analyses of sediment and liquid
samples from the sedimentation pond. (This overlaps with the first bullet above.)
Core samples from the cell(s) receiving the wastes to a depth corresponding to the leachate collection system. A
complete analysis of the cores samples as a function of depth for radioactive constituents and semi-volatile,
non-volatile organic constituents along with a complete metal analysis. (I am most concerned about the metals.)
Probe surveys to assess the vertical radiation profile levels by lowering a probe in the drilled hole where the
core sample was obtained.
Note: Core and probe analyses is required to be developed by establishing a grid with statistically derived
sampling locations to obtained an acceptable confidence level.
A complete chemical and radioactive material aAalysis for characterization of leachate, and monitoring of
leachate on a quarterly basis for an appropriate suite of parameters based on waste analysis.
A complete chemical and radioactive materials aAalysis for characterization of the surface water, and monitoring
of surface water on a quarterly basis for an appropriate suite of parameters based on waste analysis.
A complete chemical and radioactive materials aAalysis for characterization of the monitoring wells, and
monitoring of groundwater on a quarterly basis for an appropriate suite of parameters based on waste analysis.
GP991
An assessment of hazard and risk associated with potential releases of radioactive constituents or decay
products into the air.

Subject: RE: Assessment of TENORM Contamination at Blue Ridge
Blue Ridge Landfill is required to conduct an assessment of the potential contamination of the landfill and surrounding
areas resulting from the receipt of TENO RM waste from companies in Ohio as well as the processed TENO RM waste that
was received from Fairmont Brine Processing from West Viriginia.
The assessment needs to include the following:
An evaluation of all potential exposure routes of waste material to receptors both at the landfill and off-site
based on how the waste was received and managed by the landfill.
A survey of radiation levels taking into account the radiative constituents present in the waste shipments
received by the landfill to assess the extent of contamination (area) including all property owned by the landfill.
An assessment of background radiation levels contributed by shale at the site. This can potentially be assessed
by surveying for radiation levels beyond the zone of contamination and considering the geography of the
site. The goal is to distinguish between radiation levels contributed by the waste and background levels.
Analysis of shale samples at the site to identify any unique characteristics that differ from the waste containing
shale residue from Ohio and West Virginia areas.
A detailed radiation survey that assesses any potential risk presently to landfill operators and management
activities at the site.
Assessment of contaminated runoff (stormwater, etc.) from the site along with analyses of sediment and liquid
samples from the sedimentation pond.
complete analysis of the cores samples as a function of depth for radioactive constituents and semi-volatile,
non-volatile organic constituents along with a complete metal analysis.
Note: Core and probe analyses is required to be developed by establishing a grid with statistically derived
sampling locations to obtained an acceptable confidence level.
A complete chemical and radioactive material analysis for leachate .
A complete chemical and radioactive materials analysis for the monitoring wells .
(jeorge P. PartridiJe Jr.

Frankfort, KY 40601
{502) 564-6716 ext. 4651
GP992
2
le
GP993

.rom:

Weems, George (EEC)
RE: Manifests
Sent:
To:
Subject:
George;
I have been working on a list of items that we feel is appropriate to include in a site survey. I got the input of Todd
Hendricks in our Section as well. Presently I am combining my suggestions with Todd's and then I will send them to
you. Once you have looked at them, I will send the list to Curt Pendergrass and have him make any suggestions on how
to combine our request into a couple of sentences or so appropriate for an NOV and be sure to include any specific
terminology that may be appropriate.
I just want to be sure the way we request the "comprehensive site survey" that when a plan is proposed or submitted to
us we can hold them accountable for getting them all the information we need to characterize the extent of the
contamination and the associated risks.
Will have something to you for your review in the next few minutes.
-nkyou,
George
"'-----~-----------------------
___,,,,,,,,,,,,,,, . ,,,,,,,,,,,,,,,' .,,,,

Ok, I'll put that in and the Friday request I emailed. I imagine he's trying to get his upper management on this too so

George;
asented him and provide all the manifests for Fairmont Brine. When I learned that additional companies were
ding wastes to Blue Ridge, on Friday morning I again requested manifests and extended my request to include all
. a l l the manifests for 2015 and January 2016.
George
GP994

Subject: Manifests
Hey George,
GP995
2

.From:
Sent:
To:
Subject:
Weems, George (EEC)

RE: Manifests
I am going to have Lindsey email Dan Fleshour to bring your manifests for the meeting.

George;
i have been working on a list of items that we feel
is appropriate to include in a site survey. I got the input of Todd

Hendricks in our Section as well. Presently I am combining my suggestions with Todd's and then I will send them to
you. Once you have looked at them, I will send the list to Curt Pendergrass and have him make any suggestions on how
to combine our request into a couple of sentences or so appropriate for an NOV and be sure to include any specific
.minology that may be appropriate.
I just want to be sure the way we request the "comprehensive site survey" that when a plan is proposed or submitted to
us we can hold them accountable for getting them all the information we need to characterize the extent of the
.contamination and the associated risks.
,
Will have something to you for your review in the next few minutes.
Thank you,
George

Ok, I'll put that in and the Friday request I emailed. I imagine he's trying to get his upper management on this too so

t: Monday, February 15, 2016 11:56 AM
Weems, George (EEC)
George;
GP996
._.....----
presented him and provide all the manifests for Fairmont Brine. When I learned that additional companies were
waste received so we could identify all companies sending TENORM waste to Blue Ridge. On Friday I wanted copies of
all the manifests for 2015 and January 2016.
George

Monday, Feofl.iafY 1s,-20T61T:2f1AM
Subject: Manifests
Sent:
Hey George,
GP997
2
.rom:
Sent:
To:
Cc:
Subject:

. Weems, George (EEC)
Litchfield, Arline (EEC); Hendricks, Todd (EEC)
FW: RE: Assessment of TENO RM Contamination at Blue Ridge
George;
Here is my list of what needs to be included in a site survey. I have merged my items with notes and suggestions from
Todd Hendricks as well.
(Todd and Arline please look at this as well to see if my list capture all you recommendations and changes to my original
draft.)
George

bject: RE: RE: Assessment of TENORM Contamination at Blue Ridge
constituents present in the waste shipments received by the landfill. This includes in waste placement in the
disposal cell area as well as assessment of contaminated runoff (stormwater, etc.) from the site along with
analyses of sediment and liquid samples from the sedimentation pond.
An assessment of naturally-occurring background radiation at the site. Background radiation levels shall be
determined in onsite areas proven to be unaffected by waste constituents, or offsite at an approved location
that is geologically similar to the landfill
An evaluation of allpotential exposure pathways of the radioactive waste material to human and environmental
receptors both at the landfill and off-site. This evaluation shall consider the manner in which the waste was
received and managed by the landfill.
A detailed survey that assesses the present radioactive hazard and associated risk to landfill personnel.
complete analysis of the core samples as a function of depth for radioactive constituents and semi-volatile, nonvolatile organic constituents along with a complete metal analysis. Note: Core and probe analyses is required to
be developed by establishing a grid with statistically derived sampling locations to obtained an acceptable
confidence level.
A complete chemical and radioactive characterization of leachate, and monitoring of leachate on a quarterly
basis for an appropriate suite of parameters based on waste analysis.
GP998
___ _
A complete chemical and radioactive characterization of the surface water, and monitoring of surface water o.n a
quarterly basis for an appropriate suite of parameters based on waste analysis.
A complete chemical and radioactive characterization of the monitoring wells, and monitoring of groundwater
on a quarterly basis for an appropriate suite of parameters based on waste analysis.
(jeorge T. TartridiJe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP999
2
.rom:
Sent:
To:
Cc:
Subject:
Weems, George'(EEC)
RE: RE: Assessment of TENORM Contamination at Blue Ridge
Todd has covered it. I bet CHFS doesn't change it unless they want to do a lesser survey. I can't see any area they can
add to it.

Cc: Litchfield, Arline (EEC); Hendricks, Todd (EEC)
Subject: FW: RE: Assessment of TENORM Contamination at Blue Ridge
George;
. d Hendricks as well.
draft.)
.George

Subject: RE: RE: Assessment of TENORM Contamination at Blue Ridge
An evaluation of all potential exposure pathways of the radioactive waste material to human and environmental
e.
GP1000
confidence level.
Acomplet~chemical-anci
radioactive characterization of the surface water,and monitoring of surface water on a quarterly basis for an appropriate suite of parameters based on waste analysis.
<]eorge P. PartrU:(ge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1001
2
.rom:
Sent:
To:
Cc:
Subject:
Weems, George (EEC)

add to it.

George;
wd
Hendricks as well.
draft.)
.George

. To: Partridge, George (EEC)
e.
complete analysis of the core samples as a function of depth for radioactive constituents and semi-volatile, nonvolatile organic constituents along with a complete metal analysis. Note: Core and probe analyses
is required to
GP1002
confidence level.
basis for an,appropriate suite of parameters based on waste analysis.
A complete chemical and radioactive charac:;terization ofthe surface water, and monitoring of surface water"on
An assessm~nt of hazard and risk associated with potential releases of radioactive constituents or decay
a-
(jeorge P. PartrU(ge Jr.

Frankfort, KY 40601
{502) 564-6716 ext. 4651
GP1003
2

.rom:
Sent:
To:
Cc:
Subject:

Pendergrass, Curt (CHFS DPH); Keffer, Christopher (CHFS Rad Hlth)
Hendricks, Todd (EEC); Litchfield, Arline (EEC); Weems, George (EEC)
FW: RE: Assessment of TENORM Contamination at Blue Ridge
Curt and Chris;

We have been having internal meetings within the Division of Waste Management to discuss the next step as we
address the contamination from TENORM along with the waste materials that were sent from Fairmont Brine Processing
to the Blue Ridge Landfill in Irvine, Kentucky.
At this point, we plan to request/require Advance Disposal who manages the landfill to conduct an assessment of the
site to determine the extent of the contamination along with the potential impact to both ecological and human
receptors. I think of terms such as Environmental Impact Assessments (EIAs) and Risk Assessments which include the
hazard identification and exposure assessments, etc.
Please review the list of items we are interested in exploring that are provided below.
teed to take our objectives and condense it all down into a sentence or two that can be submitted with a formal
request to the management company of the landfill. They will be required to develop a plan for our review and
approval. It is important the request be presented in such a way that the Advanced Disposal will understand the scope
. f what we are asking for and develop a suitable plan.
I would appreciate any assessment terminology or type of surveys, etc. that you Branch conducts that should be
included in the language of the request. We plan to finalize the notice by Tuesday, February 16, 2016.
Thank you for your assistance, we look forward to hearing from you!
George
Assessment of TEN ORM and Waste from Fairmont Brine Processing at Blue Ridge Landfill
constituents present in the waste shipments received by the landfill. This includes in waste placement in the disposal
cell area as well as assessment of contaminated runoff (stormwater, etc.) from the site along with analyses of sediment
and liquid samples from the sedimentation pond.
received and managed by the landfill .
GP1004
confidence level.
. A ~ornplete chemical and radioactive characterization of leac:hate, and monitoring of leachate oh a quarterly
A complete chemical and radioactive characterization of the surface water, and monitoring of surface water on a
(jeorge P. 'Partridge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1005
2
.rom:

Weems, George (EEC)
Sent:
To:
Subject:
George,
Thank you! I will pass on any suggestions we received from the Curt's group as I get them.
How do you want to word the NOV in terms of a site survey. It is important that Advance Disposal knows we want to
conduct a thorough site characterization that assesses the extent of the contamination as well as potential hazards that
may have been created from its management.
Let me know you thoughts,
Thank you,
e . . . . . . .-.,. . . . . . . . . . - - - - .- . . . . . . . . . . . . . . . . . . . .
George
--~ ~
&_o: Partridge, George (EEC)
w:-c: Litchfield, Arline (EEC); Hendricks, Todd (EEC)

add to it.
sent: Monday, February 15, 2016 2:19 PM


George;
Todd Hendricks as well.
draft.)
ent: Monday, February 15, 2016 2:01 PM

GP1006
An evalt:1ation of all potential exposure pathways of the radioactive waste material to humanandeiwironmental
confidence level.
(jeorge P. Partricfge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1007
2
Partn.d ge, George (EEC)
.From:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney;
Thank you for sharing what you found!
George

To: Maybriar, Jon (EEC); Partridge, George (EEC); Hall, Karen (EEC)
Subject: RE: Green Valley Landfill Inspection Report 02-04-16
I was reviewing the Green Valley Landfill permit issuance sheet and I know why (or one reason) the Fairmont WV waste
went to Advanced Disposal Blue Ridge Landfill. Marion County WV isn't an approved source/county for the landfill.
.dney
e!o:
Maybriar, Jon (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems, George (EEC); Hall, Karen (EEC)
Jon,
Thanks,
Rodney
GP1008
.rom:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney;
I reviewed your inspection report and it reflects what we observed.

Thank you for sharing with me. It is helpful to me to learn more about how inspection visits are documented.
George

.bject: Green Valley Landfill Inspection Report 02-04-16
Jon,
. n d start on the NOV.
Thanks,
Rodney
GP1009
!rtridge, Geo'ie (EEC)

.rom:
Sent:
To:
Subject:

RE: Waste Management at TENORM
Curt;
Thanks for helping us understand better how ATS ended up with the contract. Talking with Cory Hoskins when we
visited him at his office in West Liberty, he indicated that no testing was done and the waste was shipped to the landfill
with no prior pretreatment. It would be interesting to know what WM would have charged FBP to manage the
waste. Knowing the tipping fees at Blue Ridge, we would have an idea of what Cory cleared in his contract with FBP
after of course adjusting for the transportation costs.
I am concerned that he may be fined an amount which is only a small percentage of what he cleared and that will not
discourage him from future environmental related business ventures or discourage others that would potentially
attempt the same thing.
Our Division is presently issuing NOVs to both Green Valley Landfill and Blue Ridge Landfill related to their acceptance of
a'JORM. We also plan to require a site survey or assessment at Blue Ridge to assess the extent of the contamination
d provide the basis for developing a plan to address it. In a separate email message, I shared what we want to learn
about the site and requested your input on the wording, methodologies, or terminology that needs to be used reflective
. o f the nature of the waste you Branch regulates.
Thank you,
George
To: Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth)
Subject: FW: Waste Management at TENORM
Sent:
(http://www.oilandgasawards.com/sponsor/shalewater-solutions/) and the man who invented that
disposal in KY. Below is a link to the closest WM facility that I could find that processes E&P .and
. u r t Pendergrass, Ph.D.
GP1010
Mailstop HSlC-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
-that anyuse1 dissemination, forwarding, printing; or copying ofthis e-mail is
herein.

Subject: wm
Gallia County Landfill


Bidwell, OH 45614
Details
Map
New Search
Non-Hazardous
Auto Shredder Fluff

Biosolids
E&P Wastes
https:Uwww.wmsolutions.com/locations/details/id/15
GP1011
2
Aliation Health Branch

~ East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
herein .
GP1012
.rom:
Sent:
To:
Subject:
Maze, Rodney (EEC)

Maybriar, Jon (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems, George
Re: Green Valley landfill Inspection Report 02-04-16
Any word from Daniel Cleveland on the Green Valley inspection report
Thanks
Rodney
Rodney Maze
Jon,
Attached is a copy of the Green Valley landfill inspection report. Please review and if everything looks
OK I will lock it and start on the NOV.
Thanks,
Rodney
<DWMCEI020416.pdf>
GP1013
.From:
Sent:
To:
Subject:

Maze, Rodney (EEC)
Rodney:
Have not heard anything from Daniel Cleveland yet. Also waiting to see the inspection report for Blue Ridge and what
George Weems is working on for us. I will text or email you as soon as I learn something.
Thank you,
George Partridge

Subject: Re: Green Valley Landfill Inspection Report 02-04-16
. y word from Daniel Cleveland on the Green Valley inspection report
Thanks
Rodney
Rodney Maze
Jon,
Attached is a copy of the Green Valley Landfill inspection report. Please review and if everything looks
Thanks,
Rodney
<DWMCEI020416.pdf>
GP1014
.rom:
Sent:
To:
Subject:
Maze, Rodney (EEC)

Maybriar, Jon (EEC); Partridge, George (EEC); Weems, George (EEC); Hall, Karen (EEC);
Thomas, Richard F (EEC)
Fwd: Green Valley Landfill Inspection Report 02-04-16
I will include the language in the inspection report as Daniel suggested. Any word on the technical language for the
surface scan.
Rodney
Rodney Maze
From: "Maybriar, Jon (EEC)" <Jon.Maybriar@ky.gov>
'
Date: February 15, 2016 at 4:47:11 PM EST

Subject: FW: Green Valley Landfill Inspection Report 02-04-16
Sorry. Forgot to send it to you

Looks fine to me. My only comment might be to identify where the compact is in KRS, a la " ..
.Compact, as adopted by KRS 211.859."

2 Hudson Hollow
Frankfort, KY 4060i
ph.(502) 564-2356 ext. 640
fx. (502) 564-92i2
Daniel. Cleveland@ky.gov
From: Maybriar, Jon (EEC)

Daniel,
GP1015
These will be the violations going into the NOV

To: Maybriar, Jon (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems, George (EEC); Hall,
Karen (EEC)

Jon~-
-- --
Attached is a copy of the Green Valley Landfill inspection report. Please review and if everything looks
Thanks,
Rodney
'
GP1016
Maze, Rodney (EEC)

Re: Green Valley Landfill Inspection Report 02-04-16
.From:
Sent:
To:
Subject:
Thanks George
Rodney Maze
Not yet. After the meeting we met with Tim Hubbard to discuss site assessments. He referred us to
Curt Pendergrass who I was planning to follow up with already.
I called and left a message and also sent Curt an email message. He has my cell phone number. As
soon as I hear back from him I will get in contact with you.
'
Thank you,
George

To: Maybriar, Jon (EEC); Partridge, George (EEC); Weems, George (EEC); Hall, Karen (EEC); Thomas,
Richard F (EEC)
Subject: Fwd: Green Valley Landfill Inspection Report 02-04-16

I will include the language in the inspection report as Daniel suggested. Any word on the technical
language for the surface scan.
Rodney
Rodney Maze
From: "Maybriar, Jon (EEC)" <Jon.Maybriar@ky.gov>

Date: February 15, 2016 at 4:47:11 PM EST
Sorry. Forgot to send it to you

GP1017
Looks fine to me. My only comment might be to identify where the compact is in KRS, a
la " .. ,Compact, as adopted by KRS 211.859."

2 Hudson Hollow
Frankfort, KY 40601
ph.(502) 564-2356 ext. 640
fx. (502) 564-9212
.. Daniel. Cleveland@ky.gov
From: Maybriar, Jon (EEC)

Daniel,
These will be the violations going into the NOV

To: Maybriar, Jon (EEC); Partridge, George (EEC); Thomas, Richard F (EEC); Weems,
George (EEC); Hall, Karen (EEC)
Jon,
Attached is a copy of the Green Valley Landfill inspection report. Please review and if
everything looks OK I will lock it and start on the NOV.
Thanks,
Rodney
GP1018
")
'artridge, George (EEC)

.From:

Keffer, Christopher (CHFS Rad Hlth); Garrity, Patrick (EEC); Stewart, Kevin (EEC);
Higginbotham, Jeri (EEC); Hendricks, Todd (EEC)
RE: Sign-In Sheet for February 9, 2016 Meeting to Discuss TENORM Wastes
Sign-in Sheet - DOW-DWM-CHFS Rad Hlth - 020916.pdf
Sent:
To:
Cc:
Subject:
Attachments:
Curt:
Please find attached the scanned sign-in sheet from our February gth, 2016 meeting that was held at your offices.
I scanned the sign-in sheet and also attached the email correspondence between Chris and I as we planned and
scheduled the meeting.
Thank you again for the opportunity to meet with you and your staff and those associated with your Branch and
Division.
forge
9eorge P. Partridge Jr., Pfi'D, P.'E., Q,'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1019
on a quarterly basis for an appropriate suite of parameters based on waste analysis .
(jeorge P. Partridge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1020
'rtridge, George (EEC)

.From:
Sent:
To:
Subject:
Weems, George (EEC)

Manifests
Billy said yesterday they'd be here today .
GP1021
lrtridqe, George (EEC)

.rom:
Sent:
To:
Cc:
Subject:

Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth)
Hendricks, Todd (EEC); Litchfield, Arline (EEC); Weems, George (EEC); McKinley, Matthew
W (CHS-PH); Fowler, Kathy L (CHFS PH)
Thanks George for sharing your agency's proposed plan of action to address the TENO RM contamination at Advanced
Disposal Blue Ridge landfill in Irving, KY. Would it be possible to share a copy of this Notice to the landfill With us before
you send it to your permittee today? The good news is that there are plenty of licensed radioactive decontamination
and disposal companies that perform the monitoring and analysis activities specified in your draft notice (see
https:ljwww.crcpd.org/StateServices/CommercialServices/RadWasteBrokerServices.pdf ). Several of those companies,
notably Chase Environmental, Safety and Ecology, North Winds and TriEco, all have specific licenses granted by our
office to conduct these types of licensed activities here in KY. Not to mention the fact that there are numerous NE LAP
certified environmental testing laboratories qualified to perform the required radiochemical analysis (http://nelacinstitute.org/content/NELAP/accred-bodies.php ).
Regards,
. t Pendergrass PhD
75 East Main Street
Mailstop HSlC-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax:502-564-1492
Dispose of un!'anted sources http:ljwww.crcpd.org/StateServices/SCATR.aspx

To: Pendergrass, Curt (CHFS DPH); Keffer, Christopher (CHFS Rad Hlth)
Cc: Hendricks, Todd (EEC); Litchfield, Arline (EEC); Weems, George (EEC)
.and Chris;
We have been having internal meetings within the Division of Waste Management to discuss the next step as we
ddress the contamination from TE NORM along with the waste materials that were sent from Fairmont Brine Processing
o the Blue Ridge Landfill in Irvine, Kentucky.
GP1022
At this point, we plan to request/require Advance Disposal who manages the landfill to conduct an assessment of the
site to determine the extent of the contamination along with the potential impact to both ecological and human
receptors. I think of terms such as Environmental Impact Assessments (EIAs) and Risk Assessments which include the
hazard identification and exposure assessments, etc.
Please review the list of items we are interested in exploring that are provided below.
I need to take our objectives and condense it all down into a sentence or two that can be submitted with a formal
request to the management company of the landfill. They will be required to develop a plan for our review and
approval. it is imporfant the reques1:6epresented in such away that the Advanced Disposal will understand the scopeof what we are asking for and develop a suitable plan.
I would appreciate any assessment terminology or type of surveys, etc. that you Branch conducts that should be
included in the language of the request. We plan to finalize the notice by Tuesday, February 16, 2016.
Thank you for your assistance, we look forward to hearing from you!
George
Assessment of TEN ORM and Waste from Fairmont Brine Processing at Blue Ridge Landfill
constituents present in the waste shipments received by the landfill. This includes in waste placement in the disposal
cell area as well as assessment of contaminated runoff (stormwater, etc.) from the site along with analyses of sediment
and liquid samples from the sedimentation pond.
An evaluation of all potential exposure pathways ofthe radioactive waste material to human and environmental
confidence level.
GP1023
'rtridge, George (EEC)

.From:
Sent:
To:
Cc:
Subject:

Keffer, Christopher (CHFS Rad Hlth); McKinley, Matthew W (CHS-PH); Fowler, Kathy L
(CHFS PH)
RE: Waste Management at TENORM
George,
If we prosecute ATS to the fullest extent of the law as authorized by KRS 211.869, I believe we can impose significant
fines that will not only punish ATS but prevent this ever from occurring again here again in KY. And hopefully the word
will get out to Fairmont Brine and Shalewater Solutions and other companies in OH and WV in the business of
processing wastes from oil and gas exploration and production fluids in other states that KY landfills are not open for
business when it comes to accepting these out-of-state wastes and the fines they will potentially incur should they
accept those wastes far outweigh the little bit of money they make off of these shipments.

th any administrative regulations promulgated pursuant to KRS 211.859 or
... 1.865, or fails to comply with ariy order of the cabinet issued pursuant to KRS
ten
thousand dollars ($10,000) nor more than one hundred thousand dollars
'
offense.

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
~
".H1f J~mtfi~ ' fi;;.i\tt' I
if~~:_,. ,,~,.._~.~'"''m
M"M

Subject: RE: Waste Management at TENORM
Curt;
.~ ~M .--"'""'"''''''''"'~'"'"''"'''"'
GP1024
Thanks for helping us understand better how ATS ended up with the contract. Talking with Cory Hoskins when we
visited him at his Office in West Liberty, he indicated that no testing was done and the waste was shipped to the landfill
with no prior pretreatment. It would be interesting to know what WM would have charged FBP to manage the
waste. Knowing the tipping fees at Blue Ridge, we would have an idea of what Cory cleared in his contract with FBP
after of course adjusting for the transportation costs.
I am concerned that he may be fined an amount which is only a small percentage of what he cleared and that will not
diSC()Urage him frorn_fl1,tUte eri\/ir,<Jnmental, re!l~te~ blls_ine!SS v~entljres~~dis_c_our~ge others that would P()ten~ially
attempt the same thing.
Our Division is presently issuing NOVs to both Green Valley Landfill and Blue Ridge Landfill related to their acceptance of
TENO RM. We also plan to require a site survey or assessment at Blue Ridge to assess the extent of the contamination
and provide the basis for developing a plan to address it. In a separate email message, I shared what we want to learn
about the site and requested your input on the wording, methodologies, or terminology that needs to be used reflective
of the nature of the waste you Branch regulates.
Thank you,
George

To: Partridge, George (EEC); Keffer, Christopher (CHFS Rad Hlth)
Subject: FW: Waste Management at TENORM
(http://www.oilandgasawards.com/sponsor/shalewater-solutions/) and the man who invented thcit
disposal in KY. Below is a link to the closest WM facility that I could find that processes E&P and

Mailstop HS1C-A
Frankfort, KY 40621
Telephone: 502-564-3700 ext. 4183
Fax: 502-564-1492
This e-mail and any files are protected by'the Electronic Communications Privacy
GP1025
--1ibited. If you have received this e-mail in error, please notify the sender
...,.,replying to this message and delete this e-mail immediately. Nothing in this
herein.
------
---------------~---~--~------------

Subject: wm
Gallia County Landfill

Bidwell, OH 45614
Details
Map
NewSearch
. Non-Hazardous
Auto Shredder Fluff

Biosolids
E&P Wastes
https://www.wmsolutions.com/locations/details/id/15

Mailstop HS1C-A
Frankfort, KY 40621
'A:lhone: 502-564-3700 ext. 4183
f!!!!IP. 502-564-1492
GP1026
herein.
'
GP1027

.rom:

Keffer, Christopher (CHFS Rad Hlth); Garrity, Patrick (EEC); Stewart, Kevin (EEC);
Higginbotham, Jeri (EEC); Hendricks, Todd (EEC); McKinley, Matthew W (CHS-PH);
Fowler, Kathy L (CHFS PH)
RE: RE: Sign-In Sheet for February 9, 2016 Meeting to Discuss TENORM Wastes
Sign-in Sheet - DOW-DWM-CHFS Rad Hlth - 020916.pdf
Sent:
To:
Cc:
Subject:
Attachments:
Thanks George for sending along a copy of the attached meeting sign-in sheet. Any word from US EPA on whether or not
companies involved in the processing of oil and gas exploration and production fluids are still able to classify their end
products as "special wastes"? As you so astutely pointed out at our meeting, companies like Fairmont Brine Processing
are in the waste processing business and the "special wastes" from O&E operations are their feedstock and the actual
products of their activities bear no resemblance to what they started with having TENORM radionuclide concentrations
far in excess of what they receive from their customers.
- 5 East Main Street
~ailstop HS1C-A
Frankfort, KY 40621
. e l : 502-564-3700 ext. 4183
Fax: 502-564-1492
Vt!llfU~~.
ry,_
.. .,,,.~. .
'4 .
i{j!i,~JAt1ttN~H~1t.tfl
From:
To:
Cc: Keffer, Christopher (CHFS Rad Hlth); Garrity, Patrick (EEC); Ste\,\lart, Kevin (EEC); Higginbotham, Jeri (EEC);
Subject: RE: Sign-In Sheet for February 9, 2016 Meeting to Discuss TENORM Wastes
Curt:
Please find attached the scanned sign-in sheet from our February 9th, 2016 meeting that was held at your offices.
I scanned the sign-in sheet and also attached the email correspondence between Chris and I as we planned and
.cheduled the meeting.

Thank you again for the opportunity to meet with you and your staff and those associated with your Branch and
GP1028
Division.
George '
<gearge 'P. 'PartridiJe Jr., 'Pfi'D, 'P.'E., Q'E'P

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1029
Partrid2e George (EEC)

.rom:
Sent:
To:
Cc:
Subject:

Brock, Stephanie C (CHS-PH)
Keffer, Christopher (CHFS Rad Hlth); Fowler, Kathy L (CHFS PH); McKinley, Matthew W
(CHS-PH); Partridge, George (EEC)
RE: Advanced Disposal - Blue Ridge Landfill samples
Hello Stephanie,
. I am going to have to let Chris answer your questions regarding the samples he took at Blue Ridge Landfill.
But thanks for expediting the processing of those samples just the same. I don't believe any of us thought for a moment
that the WV sludge dumped at the Advanced Disposal landfill in June of last year (radiochemical analysis of which I
included in my e-mail) were going to be anywhere near the surface and easily availa.ble for sampling 8 months later. One
of the fellows in waste management did a back of the napkin calculation at our recent meeting to discuss this issue and
estimated that literally thousands of tons of waste and debris had been dumped at the site since this TE NORM was
disposed of. And since Ra-226/Ra-228 have limited solubility in water and given the high dilution factor in the combined
landfill leachate well from which this water sample was taken, it is not surprising you saw nothing above minimal
detectable activity in the liquid.
-uick question though. You indicated that the wet 100 g sample of cover material you analyzed contained 6 pCi/g Ra226. I am assuming had the sample been dry and allowed to ingrowth for the desired 21 days, the actual activity
.oncentration of 6 pCi/g would have been much higher. The reason I bring this up is because our friends in EEC division
of solid wastes and hazardous wastes have discovered an uptick in the receipt of waste shipments from OH in the past
year at this landfill and others here in KY. OH has some of the most restrictive TENO RM regs in the US. No OH landfill can
accept TE NORM at greater than 5 pCi/g Ra-226 above natural background. The oil and gas exploration and production
wastes being generated in OH may very well be coming to KY landfills and used as daily landfill cover to overlay wastes
and debris. I know Chris said Blue Ridge landfill and the surrounding areas contained lots of shale high in NORM but I
wasjust wondering if the slightly elevated Ra-226 you show in your analysis could be due to out-of-state TENO RM being
used as daily cover? Obviously, we would need to actually sample this material being received from OH to see if it
exceeded the acceptable OH landfill dumping TENO RM limit.
Thanks,

Mailstop HS1C-A
Frankfort, KY 40621
Tel: 502-564-3700 ext. 4183
Fax: 502-564-1492
i i : curt.pendergrass@ky.gov
site: http://www.chfs.ky .gov Id ph/rad ioactive. htm
e notified of proposed regulation changes https://secure.kentucky.gov/Regwatch/
GP1030
From: Brock, Stephanie C (CHS-PH)

Cc: Keffer, Christopher (CHFS Rad Hlth); Fowler, Kathy L (CHFS PH); McKinley, Matthew W (CHS-PH)
Subject: RE: Advanced Disposal - Blue Ridge Landfill samples

Curt,
I have a couple of questions:
1. What depth was the solid sample collected from?
2. Was it from the waste or from the fill or from the cap material?
The solid sample was analyzed wet with an approximate 100 gram geometry by gamma spec yesterday. We usually dry,
grind and weigh solid samples before analysis. Also for Ra-226 analysis, we usually seal the container for approximately
21 days to allow for ingrowth. For Ra-226 analysis by gamma spec, we look for the daughters, Pb-214 and B-214,
because the peak for Ra-226 is also the peak for U-235 so there is interference when analyzing directly for Ra-226. The
wet analysis yesterday of the approximate 100 gram geometry when analyzed for Pb-214 and Bi-214 showed around 2-4
pCi/g. Ra-226 was then added to the library then re-analyzed. It showed about 6 pCi/g of Ra-226. If this solid sample
came from the waste, I would expect to have seen results more significant based on the sample results sent in the email
below.
The liquid sample was counted yesterday by gamma spec directly in the sample container it was sent in for two
hours. There was nothing above the minimum detectable activity.
In my opinion, I don't think we should spend any more time or resources on these samples. If we could get some
samples from the waste it may tell us more. We should probably have a plan in place with some data quality objectives
too if this is going to be a long term project.
Just FYI, we only have four gamma specs up in the lab right now (gamma 4 is out being retrofitted to be mechanically
cooled). Next week we will be moving out the old shields and moving in the new shields. We will be completely down
for a few days. We will then be down to three gamma specs (gamma 2 will not fit in a new shield) while we get the new
equipment up and running.
Please let me know if you have any questions.
Stephanie C. Brock
Radiation Health Supervisor
Radiation/Environmental Monitoring Section
Kentucky Department for Public Health
100 Sower Blvd., Ste. 108
Frankfort, KY 40601
Office: 502-564-8390
Cell: 502-382-7003
Fax: 502-564-2088

e
GP1031
.m:

Weems, George (EEC)
RE: Folder shortcut
Sent:
To:
Subject:
Let me ask Rob Mauer.

Subject: RE: Folder shortcut

I think that would be a good idea because of the importance of the documents.
'11ook forward to placing my documents in that folder so we will have things better organized and available for us both.
Thanks again for suggesting this and setting it up for us!
Hope your afternoon goes well!
George
W'!im:
&:::''''-''"""''"'"'"'''"""""''''"'-'"'~'"'""'-"'"""""''''''''"""
Weems, George (EEC)
t: Wednesday, February 17, 2016 2:29 PM


I'll make Blue Ridge Folder. Do you want it locked for just you and me?

George;
Set up the shortcut atyou showed.
Links me to the following folder and files.
Just wanted to confirm that I found the right location.
My understanding you wanted me to place the documents there so you could place them under an appropriate graybar.
Thanks again for your help and all you are doing!
rge
GP1032

Subject: Folder shortcut
Just open the word doc then copy and paste the address in it to the shortcut address bar.
GP1033
l.m:
Sent:
To:
Subject:
Weems, George (EEC)

RE: Folder shortcut
Yes. What level of confidentiality do you want? Public or private?

George;
I will notify you when I place documents in the folder. You could then place them under a Graybar in tempo and lock the
documents that way.
Would that work for you?
om: Weems, George (EEC)

t: Wednesday, February 17, 2016 2:34 PM
~ect: RE: Folder shortcut
Locking it makes me nervous on a state computer; afraid it will cause problems with the rest of the folder. Anyhow,
there is a folder there now. Maybe, if we want security, we just move it when we see a document in the folder then
erase it off zpix.

George;
Set up the shortcut as you showed.
ks again for your help and all you are doing!

..
.
George
1
GP1034

GP1035
.m:
Sent:
To:
Subject:
Weems, George (EEC)

RE: Folder shortcut
We can change the attributes later when everything is finalized.
Sent: Wednesday, February 17, 2016

2:42 PM
Public.
Only correspondence or reports that are in a draft format should be marked internal for the most part.
When I send you something, I will suggest whether it should be marked "public or internal."
Thanks,
m: Weems, George (EEC)

t: Wednesday, February 17, 2016
2:37 PM

Yes. What level of confidentiality do you want? Public or private?

George;
I will notify you when I place documents in the folder. You could then place them under a Graybar in tempo and lock the
documents that way.
Would that work for you?
George

. .ject: RE: Folder shortcut
GP1036
Locking it makes me nervous on a state computer; afraid it will cause problems with the rest of the folder. Anyhow,
there is a folder there now. Maybe, if we want security, we just move it when we see a document in the folder then
erase it off zpix.

Set up the shortcut as you showed.

Thanks again for your help and all you are doing!
George
,'
Sent: Wednesday, February 17; 2016 10:58 AM

GP1037
-m:
Subject:

Maybriar, Jon (EEC); Thomas, Richard F (EEC)
'dan.fleshour@advanceddisposal.com'; Weems, George (EEC); Briggs, Lindsey (EEC);
RE: List of Companies
Tracking:
Recipient
Delivery
Read
Maybriar, Jon (EEC)
Delivered: 2/17/2016 3:22 PM
Read: 2/17/20164:27 PM
Delivered: 2/17/2016 3:22 PM
Read: 2/17/2016 3:27 PM
Weems, George (EEC)
Delivered: 2/17/2016 3:22 PM
Read: 2/17/2016 3:22 PM
Delivered: 2/17/2016 3:22 PM
Delivered: 2/17/2016 3:22 PM
Sent:
To:
Cc:
'dan.fleshour@advanceddisposal.co
Jon and Richard;

I am working to compiled my records from several sources that identify companies potentially involved in shipment of
TENO RM from out of state .
..l,1an to have that list ready to distribute tomorrow, February
18th
unless other work assignments take precedence.
~predated the opportunity to meet with everyone this morning.

Thank you,
George
(jeorge P. PartridfJe Jr., Pfi'JJ, P.T., {.l'EP

Frankfort, KY40601
(502) 564-6716 ext. 4651
GP1038

. .m
~t:
To:
Subject:
Weems, George (EEC)

RE: RE: List of Companies
I'm planning on being in the field tomorrow to take advantage of the NOV lull but keep me in the loop.

To: Maybriar, Jon (EEC); Thomas, Richard F (EEC)
Cc: dan.fleshour@advanceddisposal.com; Weems, George (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC)
Subject: RE: List of Companies

Jon and Richard;
TENO RM from out of state.
I plan to have that list ready to distribute tomorrow, February
18th
unless other work assignments take precedence.
I appreciated the opportunity to meet with everyone this morning .

.!ankyou,
. . .rge
(jeorge P. PartridiJe Jr., Pfi'D, P.'E., Q.'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1039
Sent:
To:
Subject:
Weems, George (EEC)


Cc: dan.fleshour@advanceddisposal.com; Weems, George (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC)

Jon and Richard;
I plan to have that list ready to distribute tomorrow, February 18th unless other work assignments take precedence.
I appreciated the opportunity to meet with everyone this morning.
~ankyou,
. . . .orge
(jeorge P. Partrirljje Jr., Pfi'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1040
-m:
To:
Sent:
Subject:

Read: RE: List of Companies
Your message
To: Thomas, Richard F (EEC)
Sent: Wednesday, February 17, 2016 3:21 :44 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Wednesday, February 17, 2016 3:26:50 PM (UTC-05:00) Eastern Time (US & Canada).
GP1041
~:
To:
Subject:

Weems, George (EEC)
George;
Have a nice day tomorrow!
George

Subject: RE: RE: List of Companies


.
dan.fleshour@advanceddisposal.com; Weems, George (EEC); Briggs, Lindsey (EEC); Anderson, Danny J (EEC)
bject: RE: List of Companies
.
and Richard;
I plan to have that list ready to distribute tomorrow, February 181h unless other work assignments take precedence.
I appreciated the opportunity to meet with everyone this morning.
Thank you,
George
<george P. Partridjje _Jr., Pli'D, P.'E., Q'EP

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1042
.m:
To:
Sent:
Subject:
Maybriar, Jon (EEC)

Read: RE: List of Companies
Your message
Sent: Wednesday, February 17, 2016 3:21 :44 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Wednesday, February 17, 2016 4:27:07 PM (UTC-05:00) Eastern Time (US & Canada) .
..
1
GP1043
.m:
Sent:
To:
Subject:

Maybriar, Jon (EEC)
RE: List of Companies
Jon;
One of the reasons I wanted more time to work on the list is I am finding multiple companies with the same address and
the same contact person!
I am researching the companies and confirming the addresses and their existence.
Seems like that would have raised a flag if I was a company receiving out of state waste to be sent to a
municipal/contained landfill!
Appreciated the opportunity to meet with you and the others this morning.
Thank you for all you are doing,
George
orge'P.PartridiJeJ~
partment for Environmental Protection
O Fair Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1044
Awm:
Subject:

RE: Letter
Tracking:
Recipient
Delivery
Delivered: 2/18/2016 7:27 AM
. . . .t:
To:
Curt;
A letter was drafted and signed that I understood your Branch/Division was copied on. I was not part of any of the
discussions surrounding it or its preparation. I briefly saw a draft (when or after it was sent out) and did not feel
comfortable with what had been prepared and how it was handled.
If you receive any correspondence that is being sent out to our facilities with your Branch/Division copied on it, I would
appreciate you sending me a copy for my record.
I am very worried and concerned as I reflect on all the events that have transpired last year and this year that has
resulted in our landfills being contaminated with radioactive waste, one with a particularly high level of radioactive
contamination (Blue Ridge Landfill).
four first priority is protection of human health, I am deeply worried how we (DWM)are moving forward with
ddressing the contamination at the landfill and the impact this is going to have on the future health and well-being of
.those that were exposed.
I feel my investigation and the support I needed internally to adequately address this situation has been curtailed by my
supervisor and management.
I hope your department will do all you can address the safety and well-being of the operating personnel at the landfill,
the children and employees at the school across the street and entrance to this landfill, the innocent individuals and
their families that have been potentially exposed from truck traffic to and from the land fill and workers who potentially
transmitted contamination from the site to their homes and communities on their clothes and vehicles.
I am continuing to learn of additional companies and individuals that were involved in the TE NORM shipments beyond
just Cory Hoskins and his company.
I want to do all I can to support the work you and your Branch is doing to address TENORM and waste derived from
TENO RM (companies such as Fairmont Brine Processing) that are starting operations in surrounding states and that will
eventually be here in Kentucky as well. If we do not get this situation under control it will continue to escalate and so
many more people's lives will be adversely affected.
Thank you again for all you are doing to protect the health and well-being of us all.
George
illllfrae P. PartrUijje Jr., PfiV,
P.'E., Q,'EP
~artment for Environmental Protection

1
GP1045

Frankfort, KY 40601
{502) 564~6716 ext. 4651
GP1046
Aitom:
~t:
To:
Subject:

RE: Letter
Just heard this morning letter may not have been sent.
Please do not share my email message or copy it to anyone!
I will follow up with you!
Thank you,
George
eorge P. 'PartricfBe Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1047
A.E,om:
. . . . . nt:
To:
Subject:

RE:
I learn this morning that things are being delayed until we can all understand the regulations better and clarify the role
that each cabinet has.
Please disregard my recent email message.
Thank you,
George
(jeorge 'P. 'Partridge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1048
....,t:
A&,,.om:
To:
Subject:

RE: Letters
Curt;
It was confirmed to me this morning no letter has been sent or released. All I saw was draft that was later held by
management for further review.
No need for any concerns at this point.
I was just seeking to understand better the correspondence and relationships the two cabinets we are associated with
have as we move forward to address the regulatory issues surrounding TE NORM and waste management at our landfills.
I will continue to keep you informed as I learn things.
Thank you,
George
<george P. PartrUfge Jr.
~epartment for Environmental Protection

Al Fair Oaks Lane; 2nd Floor (SWB)

~ankfort, KY 40601
(502) 564-6716 ext. 4651
GP1049
Partridge,. George (EEC)
Ai.,m:
Subject:

RE: TENORM and Processed TENORM
Tracking:
Recipient
Delivery
Read
Anderson, Danny J {EEC}
Delivered: 2/18/2016 12:15 PM
Read: 2/18/2016 12:33 PM
Delivered: 2/18/2016 12:15 PM
Delivered: 2/18/2016 12:15 PM
~t:
To:
Cc:
Read: 2/18/2016 12:16 PM
Danny:
Blue Ridge Landfill [NOV Items]
Violation for disposing of unpermitted waste in landfill
Violation for refusal to provided requested manifests in a timely manner .
Violation for not reporting the out of state TENO RN/Processed TENO RM waste on Quarterly Waste Received
Reports when 47 shipments alone was received from one company between the dates Of July 24, 2015 and
November 16, 2015 and two other additional companies have been identified as well as having waste received
out of state TENO RM waste by the landfill facility.
'
le
Ridge Landfill [Action Items]
Immediately cease any waste placement or disturbance of temporary cover. in the vicinity of the cell (providing
adequate buffer distance) where the waste was placed from Fairmont Brine Processing from the time period of
July 24, 2015 to November 16, 2015.
Require Advanced Disposal to contract with a company to conduct a thorough site assessment to determine the
level and extent of the contamination at the site and construct/assess past and future worker/community
(school) exposure scenarios evaluating both radioactive and chemical constituents present in the processed
TENORM waste. The contract shall be with a NEFAP certified contractor (National Environmental Activities
Program for the establishment and implementation of an accreditation program for field sampling and
measurement organization) an/or "Radioactive Waste Broker and Decontamination" contractor
approved/recommended by the Radioactive Materials Section associated with the CFHS-DPH.
Required Advanced Disposal to have all employees that worked on the site during the period the waste was
received, scheduled for medical monitoring to establish a health level baseline since the exposures they
experience from the waste received have placed them at an elevated risk for lung and other cancers in the
future years.
Require Advanced Disposal to provide on-going annual medical monitoring throughout the lifetime of the
employees where exposure has been confirmed based on the required site assessment listed above. Also
include all identified receptors including students and employees at the school adjacent to and across the street
from the entrance to the landfill.
1
GP1050
- - - - - - -
--------------------
Development of a remedial plan for the waste site, addressing either removal or containment in place of the
waste along with appropriate site monitoring and deed restrictions regulating the future use of the site and any
potential disturbances to the waste. (This will potentially affect the exposure plan for the landfill!)
~
Landfills Statewide
Conduct an internal review (Solid Waste Branch) of the "Quarterly Waste Quantity Reports" for all landfills in
Kentucky for 2015 through first quarter of 2016.
From review of "Quarterly Waste Quantity Reports" identify all landfills that have received out of state waste
from counties or areas that are known as regions having high levels of 0 & G /Fracking Activities.
Request all manifests [2015-lst Quarter of 2016] from the landfills identified in Item 2 above that have
potentially received TENORM and processed or concentrated TENORM.
If additional landfills are identified beyond those we are presently aware of as receiving TENO RM or processed
TENORM, the next step is to request all the manifest from all landfills in the state for 2015-lst Quarter of 2016).
For all landfills that been identified as receiving TE NORM/Processed TENO RM, require a contractor to conduct a
screening site assessment to confirm that the landfill is presently safe for operator and no one is exposed to an
unacceptable level of radiation.
Based on the results above, develop a plan similar to Blue Ridge as needed .
----~
Long-Term Regulatory Goals
Expand our present regulations for Solid Waste to address radioactive constitutes both in terms of waste
received and monitoring requirements.
Develop special waste regulations for traditional TENORM [detectors, specifically designed mono-cells, PPE for
operators, maximum allowable quantities received during life of landfill]
Required high-level processed radioactive TENORM waste to be sent to a regulated facility licensed to receive
radioactive waste.
I hope you will find this helpful.

Please let me know if there are additional points I need to address for you or how you would like for me to edit or
prepare this materials for you in a format that best serves your need.
Thanks for the opportunity to present this to you and for all you are doing to address the concerns of our Branch.
George
(jeorge P. Partrid:ge Jr.

Frankfort; KY 40601
(502) 564-6716 ext. 4651
t
e
2
GP1051
GP1052
,,t:
Awm:
To:
Cc:
Subject:

RE: TENORM and Processed TENORM
Danny:
Violation for refusal to provided requested manifests in a timely manner.
Violation for not reporting the out of state TENO RN/Processed TENO RM waste on Quarterly Waste Received
Blue Ridge Landfill [Action Items]
Immediately cease any waste placement or disturbance of temporary cover in the vicinity of the cell (providing
future years.
employees where exposure has been confirmed based on the required 'site assessment Hsted above. Also
include all identified receptors including students and employees at the school adjacent\to and across the street
waste along with appropriate site monitoring and deed restrictions regulating the future I use of the site and any
potential disturbances to the waste. (This will potentially affect the exposure plan for thf landfill!)
Landfills Statewide
1
GP1053
TENO RM, the next step is to request all the manifest from all landfills in the state for 2015-lst Quarter of 2016].
For all landfills that been identified as receiving TE NORM/Processed TENORM, require a contractor to conduct a
Develop special waste regulations for traditional TENO RM [detectors, specifically designed mono-cells, PPE for
Required high-level processed radioactive TENO RM waste to be sent to a regulated facility licensed to receive
radioactive waste.

George
(jeorge P. 'Partridfle Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
e
2
GP1054
Sent:
Subject:
Microsoft Outlook
Delivered: RE: TENORM and Processed TENORM

Anderson, Danny J (EEC) (Danny.Anderson@ky.gov)
Subject: RE: TENORM and Processed TENORM
GP1055
- - - - - - - -
Sent:
Subject:
Microsoft Outlook

GP1056
Sent:
Subject:
Microsoft Outlook

Partridge, George (EEC) (George.Partridge@ky.gov)
GP1057
Sent:
Subject:
Partridge,
Partridge,
Thursday,
Read: RE:
George (EEC)
George (EEC)
February 18, 2016 12:16 PM
TENORM and Processed TENORM
Your message
Sent: Thursday, February 18, 2016 12:14:36 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Thursday, February 18, 2016 12:15:31 PM (UTC-05:00) Eastern Time (US & Canada) .
..
1
GP1058
Sent:
Subject:

Read: RE: TENORM and Processed TENORM
Your message
Sent: Thursday, February 18, 2016 12:14:36 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Thursday, February 18, 2016 12:32:38 PM (UTC-05:00} Eastern Time (US & Canada) .
..
1
GP1059

m:
. .t:

FW: RE: TENORM and Processed TENORM
To:
Subject:
Arline and Todd;

After our Staff Meeting this morning, Danny asked me to prepare a list of bullet items for him that that reflect my
concerns and suggestions as he prepares for his meeting with Tony Hatton this afternoon at 1:30 pm to include the
following:
1. Actions related to Blue Ridge Landfill where receipt of waste has been confirmed.
2. Assessment of potential waste disposal concerns at landfills statewide.
3. Future initiative to address these wastes.
I appreciate how everyone patiently listed to my concerns this morning that have arisen from my investigation of both
TENORM and companies that are processing TENORM, producing a waste that has potentially elevated chemical
contaminants and radioactive materials present.
Please do not hesitate to bring to our attention if there are other things that need to be considered or changed .
hanks again for the support I received from you all .

rge
- "' --
... ..........
..
...,,,.,,..
,,.,,,,,,,,, ,,_,,
'
,,,,,,,,,.,,~
,,,,,
"'''''"'''''"" " ' " '
Danny:
Blue Ridge Landfill [NOV Items)
Violation for not reporting the out of state TENO RN/Processed TENORM waste on Quarterly Waste Received
Blue Ridge Landfill [Action Items)
GP1060
- - - - - - ----
--------
Require Advanced Disposal to contract with a company to conduct a thorough site assessment to determine t h ieve! and extent of the contamination at the site and construct/assess past and future worker/community
. measurement mganization) an/or"Radioactiv.e.Waste Bmkecand De.cantamjnatiQD~' contractgr
future years.
Landfills Statewide
TENORM, the next step is to request all the manifest from all landfills in the state for 2015-lst Quarter of 2016].
GP1061
radioactive waste.

George
(jeorge P. PartrUfae Jr.

200 Fair Oaks Lane; 2nd Floor (SWB}
Frankfort, KY 40601
(502} 564-6716 ext. 4651
GP1062
A.om:
~t:
To:
Subject:

RE: RE: TENORM and Processed TENORM
That looks good to me, George.

You're doing good, necessary work. We're glad to help.
Thanks.

To: Litchfield, Arline (EEC); Hendricks, Todd (EEC)
Subject: FW: RE: TENORM and Processed TENORM
Arline and Todd;
following:
1. Actions related to Blue Ridge Landfill where receipt of waste has been confirmed.
2. Assessment of potential waste disposal concerns at landfills statewide.
3. Future initiative to address these wastes.
Please do not hesitate to bring to our attention if there are other things that need to be considered or changed.
Thanks again for the support I received from you all.
George

Danny:


1
GP1063
Violation for not reporting the out of state TENORN/Processed TENO RM waste on Quarterly Waste Received
W"'
Blue Ridge Landfill [Action Items)
_ad_e,qua!e_huffeLdJs_ta nce_)_whereJhe waste was placedJrnmf ai rm_g_rJt~rirn~ l'JQC!!_ssi ngJrpm_Jh~lirn~_p_~r_LQcl Qf__
future years.
Require Advanced Disposal to provide on-going annual medical monitoring throughout the lifetime ofthe
Landfills Statewide
from counties or areas that are known as regions having high levels of O & G /Fracking Activities.
Request all manifests (2015-lst Quarter of 2016] from the landfills identified in Item 2 above that have
potentially received TENORM and processed or concentrated TENO RM.
If additional landfills are identified beyond those we are presently aware of as receiving TENORM or processed
tJ
GP1064
--------------------------
...
----
- - --
Based on the results above, develop a plan similar to Blue Ridge as needed.

radioactive waste.

George

.200 Fair Oaks Lane; 2nd Floor (SWB)
Frankfort, KY 40601
902) 564-6716 ext. 4651
GP1065
,.,t:
Ar.om:
To:
Subject:

RE: RE: TENORM and Processed TENORM
Todd;
Thank you!
George

Subject: RE: RE: TENORM and Processed TENORM
That looks good to me, George.
You're doing good, necessary work. We're glad to help.
Thanks .
'''"""""""""""""""-'""""-""""""""''""""'''-'"""""""""""'"""
nt: Thursday, February 18, 2016 12:36 PM

: Litchfield, Arline (EEC); Hendricks, Todd (EEC)
bject: FW: RE: TENORM and Processed TENORM
Arline and Todd;

following:
1.
2.
3.
Actions related to Blue Ridge Landfill where receipt of waste has been confirmed.
Assessment of potential waste disposal concerns at landfills statewide.
Future initiative to address these wastes.
Please do not hesitate to bring to our attention if there are other things that need to be considered or changed.
Thanks again for the support I received from you all.
.re
A.::eorge
GP1066

Danny:
Violation for not reporting the out of state TENORN/Processed TENORM waste on Quarterly Waste Received
Blue Ridge Landfill [Action Items]
adequate buffer distance) where the waste was placed from Fairmont Brine processing from the time period of
future years.
Landfills Statewide
GP1067
from counties or areas that are known as regions having high levels of O & G /Fracking Activities.
For all landfills that been identified as receiving TENO RM/Processed TENO RM, require a contractor to conduct a
radioactive waste.
. nope you will find this helpful.

lase let me know if there are additional points I need to address for you or how you would like for me to edit or
George
(jeorae P. PartrU:fge Jr.

Frankfort, KY 40601
(502) 564-6716 ext. 4651
GP1068
~,
I ..
To:
Subject:

Melton, Ken (EEC)
FW: RE: TENORM and Processed TENORM
Ken;
Please do not hesitate to forward any additions or corrections you seen to Danny and I.
I appreciate you all listening patiently to me this morning.
You, especially have gone out of your way to be helpful and supportive to me since I have known you.
I do not want to become a PITA employee in our Branch!
Have a nice day!
George

c: Briggs, Lindsey (EEC)
lmy:
Blue Ridge landfill [NOV Items]
Violation for not reporting the out of state TE NO RN/Processed TENO RM waste on Quarterly Waste Received
out of state TENORM waste by the landfill facility.
Blue Ridge landfill (Action Items]
level and extent ofthe contamination at the site and construct/assess past and future worker/community
1
GP1069
future years.
He_qulre_Adllan.c~ed DispQsaUo provide on-going annual medical monitoring thro~gh()l!!_!_hE;! lifetime of!b~
Landfills Statewide
For all landfills that been identified as receiving TENO RM/Processed TENO RM, require a contractor to conduct a
Develop special waste regulations for traditional TEN ORM [detectors, specifically designed mono-cells, PPE for
radioactive waste.
GP1070
~anks for the opportunity to present this to you and for all you are doing to address the concerns of our Branch.
--.reorge
<george P. Partridge Jr.

Frankfort, KY 40601
{502) 564-6716 ext. 4651
GP1071

Emails Volume I

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Dr.

Partridge, George (EEC)

Kevin Kosko <kevink@shalemtr.com>

~ase feel free to contact me if you would like.

Kevin Koska <kevink@shalemtr.com>

From: Partridge, George (EEC) [mailto:George.Partridge@ky.gov]

George P. Partridfje Jr., Pli'D, P.'E., Q'EP

From: Kevin Kosko [mailto:kevink@shalemtr.com]

Partridge, George (EEC)

Partridge, George (EEC)

Briggs, Lindsey (EEC)

Delivered: 1/19/2016 8:22 AM

Anderson, Danny J (EEC)

Delivered: 1/19/2016 8:22 AM

Read: 1/19/2016 8:49 AM

Hatton, Tony (EEC)

Delivered: 1/19/2016 8:22 AM

Read: 1/19/2016 8:32 AM

Lindsey, Danny, and Tony;

(jeorae P. PartridfJe Jr., Pfi'D, P.'E., Q'EP

Partridge, George (EEC)

Hatton, Tony (EEC)

Partridge, George (EEC)

Anderson, Danny J (EEC)

Partridge, George (EEC)

Partridge, George (EEC)

(jeorge P. PartridiJe Jr., Pfi'D, P.'E., Q'EP

From: Kevin Kosko [mailto:kevink@shalemtr.com]

Sent: Monday, January 18, 2016 8:54 AM

From: Partridge, George (EEC) [mailto:George.Partridge@ky.gov]

Sent: Friday, January 15, 2016 7:55 PM

From: Kevin Kosko [mailto:kevink@shalemtr.com]

Sent: Wednesday, January 13, 2016 3:12 PM

To: Partridge, George (EEC)

Partridge, George (EEC)

Partridge, George (EEC)

(jeorge P. Partrirfge Jr., Pfi'D, P.'E., Q'EP

From: Partridge, George (EEC)

Sent: Tuesday, January 19, 2016 8:22 AM

"ot<cl the futme, cycle the P"' ..

Partridge, George (EEC)

Harris, Marc <marc.harris@aecom.com>

Partridge, George (EEC)

Partridge, George (EEC)

<jeorne P. PartridiJe Jr., PhD, P.E., QEP

Fair Oaks Lane; 2nd Floor (SWB)

Kentucky Revised Statues:

224.46-530 Specific authority of cabinet over management of hazardous wastes.(l)(k) To regulate

Kentucky Administrative Regulations:

, , 6 ) "Special waste" is defmed by KRS 224.50-760(l)(a).

From: Harris, Marc [mailto:marc.harris@aecom.com]

Sent: Monday, January 25, 2016 12:57 PM

Harris, Marc <marc.harris@aecom.com>

From: Partridge, George (EEC) [mailto:George.Partridge@ky.gov]

Sent: Monday, January 25, 2016 1:16 PM

<;ieorge P. Partrid{Je Jr., PhD, P.E., QEP

Kentucky Revised Statues:

224.46-530 Specific authority of cabinet over management of hazardous wastes.(l)(k) To regulate

Kentucky Administrative Regulations:

From: Harris, Marc [mailto:marc.harris@aecom.com]

Sent: Monday, January 25, 2016 12:57 PM

Subject: Sandblasting Grit - NORM waste handling

Kevin Koska <kevink@shalemtr.com>

Partrid.ge, George (EEC) [mailto:George.Partridge@ky.gov]