CCHPS Technical Meeting

November 2024

David J. Allard, MS, CHP, FHPS 

NORM and TENORM in Pennsylvania - a Case Study

Mr. Allard will be speaking to his work that provides a review of past investigations of naturally occurring radioactive material (NORM) and past and recent studies related to technologically enhanced NORM (TENORM) in the commonwealth’s Oil & Gas (O&G) industry, related radioactive waste disposal issues, and the potential worker and public radiation exposure. The DEP’s O&G Program and Bureau of Radiation Protection (BRP) examined the radium levels in conventional O&G wastewater in the early to mid-1990s. That work was resumed in 2013 due to a significant increase in unconventional O&G shale gas well development. A major “cradle to grave” O&G TENORM Study was conducted at that time, with results and all related documentation published online in May 2016. Follow-up to this Study’s results and recommendations were ongoing thru 2022, including the start of routine landfill leachate testing for radium. In that same year, revised guidance was issued for O&G operations that may generate TENORM, and are required to have an approved Radiation Protection Action Plan. Current and future challenges of implementing controls (e.g., for O&G brine road spreading), and communicating the appropriate regulatory balance for public, worker and environmental radiation protection standards as it relates to TENORM and waste disposal will be discussed.

Speaker Bio

Mr. Allard is a Medical Health Physicist, certified by the American Board of Health Physics for comprehensive practice, Fellow of the Health Physics Society, and on February 1, 1999 was appointed Director of the BRP in the Pennsylvania Department of Environmental Protection (DEP). During his DEP tenure he also served two stints as the Acting Deputy Secretary for Waste, Air, Radiation & Remediation, but always requested he [eventually] be returned to his BRP Director position. After over 23 years of service, he retired from the DEP in July 2022. Allard was responsible for: accelerator, X-ray, environmental surveillance, nuclear safety, radiological emergency response, radioactive materials, decommissioning/site clean-up, low-level radioactive waste and radon programs within the Commonwealth. He was also the technical lead on Oil & Gas industry radium and NORM/TENORM issues for DEP. BRP has about a $15M annual budget, with 100 technical and administrative staff in the DEP’s Central and Regional Offices.

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