Eastern Montanan is not North Dakota’s dumping grounds. We need radioactive oil waste rules in Montana that are as strong as North Dakota’s. Source - https://northernplains.org/rad-waste-deq-comments/The Montana Department of Environmental Quality (DEQ) is proposing new rules for the disposal of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM). This radioactive waste is generated as a result of oil/gas production. There is currently one site in Montana that receives such waste, located near Glendive. It receives waste primarily from operations in North Dakota. Three other facilities are licensed to receive TENORM, including Missoula’s Republic Services. Current Montana rules regulating these wastes are inadequate because they are the same rules that apply to standard solid waste disposal. Special rules for TENORM are required. The facility near Glendive has caused groundwater contamination that includes radioactivity in excess of drinking water standards.
Send your comment to DEQ in support of stricter standards for this waste. Refer to the document “TENORM information” and “TENORM rulemaking priorities” for background. The documents are supplied by the Northern Plains Resource Council. Use these to prepare your own comment or go to the link on the Northern Plains website. At the bottom of this Northern Plains website page, LEARN MORE ABOUT RADIOACTIVE OIL WASTE RULES.
For a sample comment, refer to the document “FO2R comment.”
The public comment period ends October 21. Send your comment by email to Sandy Sherer, DEQ Legal Secretary, This email address is being protected from spambots. You need JavaScript enabled to view it. or mail your comment to Sandy Sherer, Legal Secretary, Montana Department of Environmental Quality, 1520 E. Sixth Avenue, Helena MT 59620.
Sandy Scherer, Legal Secretary
This email address is being protected from spambots. You need JavaScript enabled to view it.
Department of Environmental Quality
PO Box 200901
Helena MT 59620
Comment regarding rules for the disposal of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM)
Friends of 2 Rivers is a grassroots citizen organization with a mission to maintain/enhance environmental quality for the benefit of citizens. Through the efforts of the Northern Plains Resource Council we have been made aware of the current shortcomings in rules that apply to disposal sites for TENORM.
We fully support all of Northern Plains’ recommendations for revising the rules, as given in their document “TENORM Draft Rules - Rulemaking Priorities” of October 1, 2019 (attached). These priorities for limiting radioactive concentration, managing storm water, requiring robust liners, monitoring leachate, responding immediately to contamination exceedances, monitoring and oversight by DEQ, and management of metal waste are essential ingredients if there is to be effective prevention of serious environmental consequences from storing this waste.
We note that in the past waste storage facilities of various types have been plagued with failures, in spite of the best intentions of engineers and state-of-the-art materials. At the current TENORM waste disposal facility near Glendive, groundwater is contaminated with radioactivity above drinking water standards. Because of the almost inevitable failures of these types of waste storage facilities, a critical part of DEQ rules is the assignment in perpetuity of liability for the environmental impacts caused by failures at TENORM storage sites. We urge DEQ to incorporate that assignment of liability into the TENORM rules.
Montanans depend upon DEQ to fully embrace our Montana Constitution and our right to a clean and healthful environment. We cannot continue to allow major corporations and “big money” to externalize the costs of their operations in our state, costs which ultimately are born by individual Montanans because of impacts to human and environmental health.