1. TENORM in Ohio Michael Snee
Bureau of Environmental Health & Radiation Protection
Ohio Department of Health
CRCPD 2017 May 8, 2017

2. TENORM regulation in Ohio
Ohio Revised Code states “The department of health is hereby designated the Ohio radiation control agency.”
Ohio Revised Code also states for the ODNR - Division of Oil and Gas Resources Management - “The division has sole and exclusive authority to regulate the permitting, location, and spacing of oil and gas wells and production operations within the state”.
OEPA regulates all landfills in Ohio where much of the waste from the oil & gas industry ends up.

3. Ohio TENORM regulations
ODH TENORM regulations in OAC Chapter 3701:1-43 are patterned on SSR Part N. We received one comment in a recent public comment period. The public comment period was for a required 5 year rule review.
OEPA has rules out for public comment that will require all landfills that accept oil & gas waste to have radiation detectors and develop and implement a Radioactive Materials Detection Program.
ODNR rules are being developed.

4. ODH TENORM issues Pipe cleaning operations.
Laboratories for analysis of Ra-226/Ra-228.
Our biggest issue was the hours devoted to TENORM issues. With the creation of the ODNR Radiation Section, this issue has been greatly alleviated.

5. TENORM in Ohio Chuck McCracken Manager, Radiation Safety Section
Division of Oil and Gas Resources Management
CRCPD 2017 May 8, 2017

6. Sole & Exclusive Authority
State of Ohio legislature codified single agency oversight of all oil and gas E&P operations to DNR.
ODH TENORM rules not directly enforceable by DNR.
DNR is promulgating radiation protection rules specific to TENORM waste management.
DRAFT rule for Waste Substances Facility construction and operations (TENORM waste solidification, down- blending etc…).

7. TENORM Regulatory Challenges Chief’s Orders vs OAC Rules
In the absence of specifically enforceable OAC rules on TENORM, the terms and conditions set forth in a Chief’s Order are statutorily enforceable.
Waste Facility Permit to Operate (must have a radiation protection program)
Regulatory Enforcement Actions (TENORM spill clean-up COC’s include Ra226 & Ra228)

8. Radiation Safety Section
est. June 13, 2016
Engineering Program: 36 Waste Substance Facilities - RPP reviews, RPP inspections.
Orphan Well Program: ± 700 wells currently – site radiological assessments prior to and post plugging.
Environmental Program: Site remediation plan approval & confirmatory surveys.
UIC Program: Tank bottoms, filter socks, management consultation on recommended actions.