PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015

APPENDIX L

PEER REVIEW COMMENT AND RESOLUTION DOCUMENT
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-1

Peer Review – PA TENORM Study Report

COMMENTS BY REVIEWER

Reviewer: Number 1

Organization: Date: 1/7/15

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

1

NA Overall, I believe the study is very 

comprehensive and demonstrates that 

while there are areas of TENORM from the 

gas and oil industry, it does not present a 

significant radiological concern.

X

Noted.

2

NA In the Study Implementation section, it 

states that gamma radiation exposure rates 

and gross gamma radioactivity surveys 

were performed at each facility using a 

Bicron Micro-Rem Meter or a Ludlum 

Model 19 Micro-R Meter, recorded in units 

of micro-Roentgen per hour (μR/hr).

However, except for the Distribution and 

End Use sites, the exposure rates are 

based on measurements taken with a 2x2 

NaI meter and a conversion factor of 800 

cpm/μRh, based on Ra-226. While this will 

give an approximation of the exposure rate, 

it is not as accurate as measurements with 

a micro-rem meter since there are likely 

other radionuclides contributing to the 

gamma exposure.

X

The gross gamma radiation 

measurements performed 

over facility areas are 

included in Appendix E. The 

extensive scan data 

collected with 2x2 NaI 

detectors were presented in 

the text as a general 

approximation of exposure 

rate over these larger areas.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-2

COMMENTS BY REVIEWER

Reviewer: Number 1

Organization: Date: 1/7/15

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

3 NA The reference to the conversion factor from 

cpm to μRh for the exposure rate 

measurements described above should 

read “Table 6.4” from NUREG-1507. X

Reference changed to

Table 6.4. The value of 800 

was selected as a one 

significant figure estimate of 

the cpm per μR/h 

conversion for Ra-226 and 

progeny.

4 Section 9 Under the Recommendations for Future 

Actions section, it recommends that 

additional radiological sampling and 

analyses, radiological surveys, and 

additional study be performed for all the 

sites evaluated in this study. The Synopsis 

section only recommends further study of 

radiological environmental impacts from the 

use of brine for dust suppression and road 

stabilization. Based on the finding of this 

study, I question whether further sampling 

and study is warranted at any of the sites, 

from a cost-benefit perspective.

X Section 9.0 includes facility 

type specific observations 

and recommendations. 

Additional actions are not 

recommended for all facility 

types.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-3

Peer Review – PA TENORM Study Report

COMMENTS BY REVIEWER

Reviewer: Number 2

Organization: Date:

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

1

3-16, 

Table3-2, 

Line 5 of 

data

Maximum value of .3 is clearly incorrect 

given a minimum of 7.44 and s.d. of 19.2 X

Data transposition error was 

corrected.

2(a)

4-2, 

para’s 

4.1.1.3 

and 

4.1.1.4

See detailed comment below table.

X

The text of Section 4.1.1.4 

points out the difference 

between the maximum 

average and maximum 

values exposure rate values 

for all POTW-I’s and 

references the tables where 

the values are further 

summarized as you state. 

The Section 4.1.6.1 external 

gamma exposure is a very 

conservative calculation 

based on the highest 

average value at any 

POTW-I and an exposure 

period of 2,000 hours/y. 

This assumes the worker is 

essentially outdoors within 

the site boundary the entire 

work year with 2 weeks offsite. The variables of 

exposure time and location 

by worker and task are 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-4

COMMENTS BY REVIEWER

Reviewer: Number 2

Organization: Date:

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

unreasonable and 

inaccurate to model beyond 

the simple conservative 

estimation presented. The 

only accurate study method 

is whole body dose 

monitoring of individuals to 

corroborate the actual 

exposure to workers.

2(b) 4-19 both 

tables

See detailed comment below table XSee response to 2(a).

2(c) 4-26 See detailed comment below table XSee response to 2(a).

2(d) 9-3, 

9.1.2.1 

2

nd bullet 

item

See detailed comment below table

X

See response to 2(a).

3 9-3, 

9.1.2.1 

last line

Apparent math error in calculation of ave. 

dose equivalent rate. 36.3 microR/hr times 

2000 hrs should be 72.6 mrem/yr, not 62.6.

X

The exposure modeled is 

for dose above background. 

The maximum gamma 

radiation exposure rate is 

reduced in the calculation 

by the local background 

value of 5 μR/h. The 

conservative estimate is 

correct as calculated.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-5

Review of Technologically Enhanced Naturally Occurring Radioactive Materials (TENOEM) Study Report as requested 

by the Pennsylvania Department of Environmental Protection (PA DEP)

Overview of review

This review primarily consisted of a review of the observations in chapter 9.0 to determine if they were reasonable and if they were supported by the data presented in 

the earlier chapters. Detailed reviews of the other chapters were not possible due to lack of time, and lack of knowledge on my part.

Sections 2.0 (Study Implementation) and 8.0 (Quality Assurance and Quality Control) both appear to be adequate for this study based on my somewhat limited 

experience with environmental sampling.

Comments on Observations from Chapter 9.0:

9.1.1 Well Sites: Observations and the conclusions based on these observations all seem reasonable and justified.

9.1.2 Wastewater Treatment Plants

9.1.2.1 POTWs I have a concern with the second bullet item in this section. Besides the simple math error in the section, I believe that the conclusion may not be 

justified. The original concern that I had was based on the data presented in the two tables on page 4-19, which are referenced from sections 4.1.1.3, and 4.1.1.4 

earlier in the report. In particular I noticed that the data for site 15 (and to a lesser extent site 17) had maximums far exceeding the other sites and a standard deviation 

that was larger than the average value. This site also had unusually high values on Table 4-13 (page 4-26). 

When I received access to Appendix E, I reviewed the gamma scam maps for site 15, which clearly showed what I expected. Namely the distribution of elevated levels 

was not randomly distributed but was highly stratified, with the elevated readings primarily in the south west corner of the site. (Note that page numbers were not 

available in Appendix E but this comment is based on the image designated as WT-15-FS-031, WT-15-FS-032, and WT-FS-033 Gamma Scan)

The conclusion presented in the last paragraph of the 2nd bullet item in 9.1.2.1 on page 9-3 concludes that there is little potential for exceeding public dose limits from 

external gamma radiation based on the highest average which was for site 15. However this average is biased by the large number of samples taken outside the 

southwest corner of the site. A stratified survey of the site with average levels for each of the strata would be a better approach in my opinion and I suspect would 

show levels that might result in doses exceeding public dose limits for workers. 

Given the low number of POTW-I’s that are in the study, I am concerned that one of the sites has a relatively elevated concentration of radioactivity and believe that 

this needs to be studied to determine if the elevated readings could be associated to drilling in the area. I am not sure that a simple conclusion can be made from this 

study regarding public dose limits for POTW-I’s, but I don’t believe that the conclusion that there is little potential for exceeding limits is justified, particularly for workers 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-6

at the plants. This is especially going to be true if drilling is related to the observed readings at this site since levels may continue to climb with continued growth in the 

drilling industry. 

9.1.2.2 and 9.1.2.3 Observations and the conclusions based on these observations all seem reasonable and justified. I looked up detailed definitions for CWT and 

ZLD facilities in order to better understand my concern with POTWs and believe that the relative number of these facilities in the State could also factor in the 

significance of the comments that I have made. It would be interesting to include in the report the total number of POTW, CWT, and ZLD facilities in the State and how 

many are impacted by drilling in order to better understand the completeness of coverage of the study.

9.1.3, 9.1.4, and 9.1.5 Observations and the conclusions based on these observations all seem reasonable and justified.

9.2 Recommendations for future Actions

I strongly endorse the 2nd bullet item in section 9.2.2 (conduct additional surveys at all WWTPs) especially if there is not a simple explanation for the elevated readings 

observed at site 15. The other recommendations also seem reasonable and justified based on the data presented in the report.

Other minor editorial comments are provided on the comment sheet. 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-7

Peer Review – PA TENORM Study Report

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

1 N/A The document is generally well-done and I 

believe covers the most notable areas 

related to naturally occurring radioactivity 

and radiation associated with current oil 

and gas generation activities in 

Pennsylvania. I have no major issues or 

areas of disagreement with the report. I 

have not attempted to make any minor 

editorial comments. What few comments I 

have are included below.

X

Noted.

2

N/A The document would benefit greatly from a 

strong and inclusive summary that presents 

the major findings of the study.

X

Synopsis added as 

Section 0.

3

N/A Because Pennsylvania is one of the 

significant players in the area of fracking 

and new gas generation, and because the 

environmental issues surrounding this topic 

are and will likely continue to be 

controversial, I believe it would be 

appropriate to issue this report in draft form 

to a number of involved and interested 

groups, agencies and individuals in an 

attempt to gain some useful feedback.

X The peer review process 

was undertaken to have a 

group of subject matter 

experts review and 

comment upon the report 

prior to release. This report 

is a discrete representation 

of the efforts associated 

with this study including the 

observations and 

recommendations for future 

actions that can be made 

based on the analytical 

results obtained. 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-8

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

Consequently, it isn’t 

necessary to issue this as a 

draft for comment. This 

report is viewed as an initial 

major effort in the collection 

of information necessary to 

effectively manage 

TENORM from O&G 

operations. Any future 

regulatory actions that 

would result from any data

or recommendations 

associated with this study 

will include an opportunity 

for public participation and 

comment.

4

N/A I did not receive copies of any of the 

appendices and therefore have no 

comments regarding them.

Noted.

5

2.1.2.3/2-

4/18

How were the samples preserved – acid 

addition or other means?

Oops – I see you refer 

to this in 3.6.2.

X See Section 2.2.2, 

page 2-6, line 24.

6

2.2.1.3/2-

6/2

When you say digested do you mean that 

the solid sample was completely dissolved, 

or was the digestion followed by filtration 

prior to coprecipitation with iron? Has the 

digestion process been demonstrated to be 

effective at removing all of the 

radionuclides of concern?

X The solid sample was 

completely dissolved. The 

DEP BOL participates and 

successfully passes 

Proficiency Testing (PT) 

samples in mixed media 

which includes soil samples, 

purchased from an 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-9

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

accredited PT provider 

Environmental Resources 

Associates (ERA). The soil 

matrix is digested and 

completely dissolved prior 

to analysis. The solid 

samples for this study were 

prepared in the same 

manner as soil PT samples. 

7

2.2.2/2-

6/24-25

Does the nitric acid addition affect solubility 

of any suspended solids?

3.6.2 again X Addressed in Section 3.6.2.

8

2.2.2.2/2-

7/12

Have you determined that the conversion to 

oxides via flaming the planchet did not 

volatilize significant Po-210, which might be 

a significant alpha emitter in Ra-226 

containing samples.

X No, the BOL has not 

determined how much if any 

Po-210 was volatilized 

during the conversion to 

oxides via flaming the 

planchet. Most of these 

samples contained very 

high levels of solids and 

were hygroscopic in nature. 

The sample matrix 

contributed significantly to 

the self-absorption of alpha 

and beta particles prior to 

reaching the detector. It was 

necessary to flame the 

planchet at high 

temperatures to convert 

nitrates to oxides even 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-10

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

though it is known, 

according to EPA research, 

that it is possible to lose 

some radionuclides such as 

polonium, lead, and cesium 

at high temperatures.

9

2.2.3/2-

7/36

The statement is that a Ludlum Model 2200 

Scaler-Ratemeter was sometimes used for 

counting scintillation cells. I assume this 

required use of a photomultiplier tube in 

conjunction with the scintillation cell and 

ratemeter. Perhaps this should be noted.

X

Section 2.2.3 line 34 was 

revised as “...collected at 

various locations using 

scintillation cells with 

photomultipier tubes 

and...”.

10

3.1.3/3-

2/25-27

It would be helpful to convert the cited 

count rates to exposure rates, since the 

count rates alone are not instructive. I 

realize Table 3-3 has a footnote stating the 

conversion factor, but results in the text 

should be explanatory without the reader 

having to do the conversion.

X

Section 3.1.3 lines 26 and 

27 have been revised as 

“...14,519 cpm 

(approximately 18 μR/h), 

and the maximum gamma 

radiation scan result 

measured was 30,823 cpm 

(approximately 39 μR/h).

11

Fig. 3-1/3-

4/3-4

Do you have an explanation for why Ra226 is so much higher than U-238 for WP12-SL-052 compared to other samples?

X

The high Ra-226 activity 

was confirmed with a 

second analysis of the 

same sample. The high 

total U result using XRF 

was also confirmed with a 

second analysis of the 

same sample. We do not 

have an explanation for the 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-11

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

activity difference between 

the two isotopes.

12 3.2.2/3-

5/9-11

In the usual application the null hypothesis 

is the hypothesis that presupposes that no 

statistically meaningful difference exists 

between the quantities being tested. 

Rejection of the null hypothesis normally 

implies acceptance of the alternative 

hypothesis. The hypothesis specified in the 

text is usually defined as the alternative 

hypothesis,

X

The test is still valid as used 

and stated.

13 Fig. 3-4/3-

6

The WP-06-SL-037 point appears to show 

a greater Ra-U difference than is typical for 

most of the points. Any comment 

necessary?

X For this sample, the Th-232 

and U-238 activities are 

higher than the Ra-226 and 

Ra-228 activities. This is 

also the only sample 

collected in the Utica 

formation in a wet gas 

region. The difference may 

be impacted by the type of 

shale formation.

14 3.3.2/3-

7/41-42

The levels are given in pCi/L with a wide 

range. I think a brief comment as to 

significance is appropriate – e.g., values 

compared to any reference values. 

The Table 2-2 criteria for 

volumetric liquids were 

referenced in Section 3.3.2.

15 3.3.3/3-

8/7-8 and 

3.3.4/3-

8/15-16

Same comment as 14. The Table 2-2 criteria for 

volumetric liquids were 

referenced in Section 3.3.2.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-12

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

16 3.4.2/3-

8/40-41

Again, a comment on significance of the 

radon levels would be appropriate.

X

The Rn in the samples 

described in Section 3.4.2 is 

from production gas that 

does not have either 

regulated criteria or project 

reference data for 

concentration comparison. 

17 3.5.1/3-

11/8

It is not clear what is meant by the “limiting 

local background gamma---“. Considering 

the Table 3-4 values, I don’t know how the 

5 microR/hr “limiting” applies. 

X

“Limiting” was removed 

from the sentence, since 

the value is for local 

background.

18 Table 3-1 It would be helpful to have a marker after 

the title refer the reader to the table up 

footnote so that the reason is specified for 

the same min and max values in many 

cases. 

X

The title has been footnoted 

to direct the reader to the 

note at the end of 

Table 3-1.

19 Table 3-2 1) It would be helpful to have some 

indication in the title or elsewhere as to the 

media being assessed. 2) Putting a 

footnote marker in the Minimum, Maximum, 

and Standard Deviation columns would

again be useful to the reader.

X

1) The title specifies surface 

and the specific location of 

the smear samples is 

located on site maps. 

There is no good way to 

specify the location in the 

table. A footnote has been 

added to generally describe 

the types of surfaces where 

samples were collected. 

2) The title has been 

footnoted to direct the 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-13

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

reader to the note at the 

end of Table 3-2.

20 Table 3-3 Again, a specification of the type(s) of 

media being assessed would be helpful. X

A footnote has been added 

to generally describe the 

types of surfaces where 

samples were collected.

21 Table 3-5 A footnote to explain the reason(s) for the 

“#N/A” entries as well as the significance of 

the “<” values in the table might be helpful. 

Also, the explanation of the use of 1⁄2 the 

MDC as the reported minimum would be 

appropriate. Similar comments apply to the 

subsequent tables.

X

All N/A values have been 

removed. Footnote 

explanations of the < values 

and 1/2 the MDC as 

reported minimum have

been added.

22 Table 3-

13

The “<565” and “<298” pCi/L values seem 

high if they represent the MDCs. Some 

explanation seems appropriate. A similar 

comment applies to some of the gross 

alpha values in Table 3-15 and Table 3-16.

X

The two Frac Phase liquid 

samples in question have 

elevated NORM activities. 

The Ra-226, Bi-214, and 

Pb-214 all have high 

activities. After reviewing 

the spectrum, the K-40 

peak is present but has a 

high MDC because the 

overall background of the 

sample is also elevated. 

The gross alpha values for 

the Frac Phase liquids are 

elevated because a small 

aliquot of sample was 

analyzed in order to keep 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-14

COMMENTS BY REVIEWER

Reviewer: Number 3

Organization: Date:12/18/2014

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

the self-absorption factor 

low.

23 Table 3-

18

Is there a reason why the median radon 

concentration is given at the bottom of the 

table, but no average value and standard 

deviation are given?

X

The average and standard 

deviation have been added.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-15

Peer Review – PA TENORM Study Report

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

1 xiv Under Condensate, define PSIA. XChange made as “pounds 

per square inch, absolute.”

2 xiv Need better definition of flowback fluid. 

Second sentence, . . . fluid used to fracture 

the target formation, including any naturally 

occurring fluids contained within the rock 

(connate or interstitial fluids).

X

Pa DEP Code Definitions.

3 xv Add word leachate and define it

X

Leachate added to the 

Glossary as “A solution 

resulting from water that 

has percolated through solid

(e.g., waste in a landfill) and 

potentially leached out 

some of the soluble 

constituents.”

4 xvi Define Proppant Sand by mentioning the 

sirf, i.e. 100 mesh (0.149 millimeters)

X

We did not find “sirf” as an 

acronym or term associated 

with proppant sand particle 

diameter, etc. The only 

mention of particle diameter 

(if the mesh size has to do 

with that) is that proppant 

sand of different particle 

size is selected for job 

specific requirements. 

5 xvi Servicing Fluids – “work over” should be 

hyphenated . . . “work-over” X

Change has been made.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-16

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

6 xvi Define Smear Sample: I imagine a round 

paper being forced to fit into a 10x10 cm 

square. Dumb I know, but that’s the mental 

image.

X

Revised definition is: “A 

sample of removable alpha 

and beta surface 

radioactivity collected by 

pressing a 47-mm diameter 

filter paper over 100 cm2of 

surface area to obtain an 

assumed fraction of 

removable material. The

filter paper is counted for 

alpha and beta radioactivity 

without any preparation.”

7 xvi Define Spent – maybe lubricants collected 

after use? X

Revision made as “Oil and 

gas drilling and/or plug 

drilling lubricants that have 

exceeded their useful life.”

8 xvi TENORM – last two lines should read: . . . 

or potential for human exposure have been 

increased BY HUMAN ACTIVITIES above 

levels concentrated . . . reads better.

X

Pa DEP Definition.

9 xvi Add Sqular Equilitrium to definitions.

X

Definition for secular 

equilibrium has been added 

as: “A type of radioactive 

equilibrium in which the 

half-life of the precursor 

(parent) radioisotope is so 

much longer than that of the 

product (daughter) that the 

radioactivity of the daughter 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-17

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

becomes equal to that of 

the parent with time.”

10 Section 

1.1, page 

1-1

Line 12 & 13. Move “by human acitivities” 

to same place as shown in Comment No. 8 

above.

X

See response to comment 

#8.

11 Section 

1.2, page 

1-3, line 2

Should “u” be “uranium (u)?”

X

No.

12 Section 

1.3, page 

1-4

Should the #’s beneath the symbols be 

defined? U-238 - half life?

 4.5x10y X

Year, day, hour, minute,

and second have been 

defined in a footnote to 

Figures 1- 3 and 1-4.

13 Section

1.4, page 

1-5, line 

12

The 1st use of the work “media” should be 

defined sooner. It does happen in end of 

line 14, but that is too late.

X

The 2nd and 3

rd sentence in 

Section 1.4 have been 

revised as: “The product 

streams evaluated are 

natural gas and natural gas 

liquids, i.e., condensates. 

Other media evaluated 

includes solid...”, to connect 

the first and subsequent 

uses of “media”.

14 Section 

1.4.1.2

Defines “drilling muds” as a liquid. Section 

2.2.1, page 2-5 defines “drilling mud” as a 

solid. Need to reflect (early) that could be 

solid or liquid as a function of % solids % 

fluid.

X

Drilling muds are liquids by 

convention on well sites. 

Methods section includes 

explanation of when muds 

were analyzed as solids by 

gamma spec.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-18

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

15 Section 

1.4.1.3, 

page 1-6, 

line 22

Many facilities are . . . Define facilities or 

reword. Tools, equipment, structures ? ? ? X

First sentence rewritten as:

“Many facilities, structures, 

and systems are utilized 

during...”

16 Section 

2.1, page 

2-1, line 5

Define “environmental media”

X

The term “environmental 

media” has been replaced 

with “solid and liquid waste, 

soils, ambient air, and 

gaseous emission products 

associated with O&G 

operations” to match the 

description in Section 1.4.

17 Section 

2.1, page 

2-1, line 9

Define “degree.” Do you mean the 

abundance? 

X

Sentence revised to replace 

“degree” with “abundance.”

18 Section 

2.1.2.1, 

page 2-3, 

line 24

“The media sampled during this study 

included:” Get rid of the work “following.” 

Poor grammar & redundant. X

Change made as 

requested.

19 Section 

2.1.2.2, 

page 2-4, 

line 5

Solids Sample Methods. Next line says 

“solid samples.” Should line 5 read, 

“sampling of solids methods” or “methods 

to sample solids?”

X

Section 2.1.2.2 title 

changed to “Solid Sample 

Methods” to match title for 

Section 2.1.2.3.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-19

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

20 Section 

2.1.2.3, 

page 204, 

line 17

“ . . . they were preserved.” Define 

preserved. Lots of methods to preserve 

stuff. Preserve for its chemical 

characteristics or physical characteristics?

X

Sample preservation is the 

measure or measures taken

to prevent reduction or loss 

of target analytes. Analyte 

loss can occur between 

sample collection and 

laboratory analysis because 

of physical, chemical, and 

biological processes that 

result in chemical 

precipitation, adsorption, 

oxidation, reduction, ion 

exchange, degassing, or 

degradation. Preservation 

stabilizes analyte 

concentrations for a limited 

period of time.

21 Section 

2.1.2.4, 

page 2-4, 

lines 37 & 

38

Rewrite. May be correct in lab jargon but 

sounds odd. Example – the natural gas 

was passed continuously through the cells 

for 10 minutes, thus purging the gas liners 

and the . . .

X

Standard method.

22 Section 

2.2.1, 

page 2-5, 

line 5

If definition of drilling muds was changed to 

include both sand & liquid, this line now 

OK.

See response to comment 

#14.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-20

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

23 Section 

2.2.1.1, 

page 2-5, 

line 12

Define “marinelli” somewhere

X

The term “Marinelli” has 

been added to the glossary 

with the definition of: “A 

lightweight polypropylene 

sample container with snapon lid used for gamma 

spectroscopy analysis.”

24 Page 2-

12 & 2-13

Table 2-2 extends over multiple pages. 

Each new page should say Table 2-2 

(cont.). This comment applies throughout 

the document for multiple page tables. X

The table titles have been 

applied across pages 

throughout the document.

25 Section 

3.1, page 

3-1, line 

37

First line, I have seen phrase “Removable 

a/ B surface.” Please define.

X

The first use of “removable” 

is in the glossary definition 

of smear sample collection 

revised in comment #6. 

The first use in the text 

occurs in Section 2.1.1.3.3, 

which also references 

sample collection with 

smears. No change made.

26 Section 

3.2.2, 

page 3-5, 

line 5

Define “student t-test” somewhere. 1st

mention of a specific statistical method.

X

Student t-test definition has

been added to the glossary 

as “A test for determining 

whether or not an observed 

sample mean differs 

significantly from a 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-21

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

hypothetical normal 

population mean.”

27 Section 

4.1.1.2, 

page 4-2, 

line 5

Add “ . . . and 10,000 dpm/100 cm2, 

respectively. First time the grammatic 

forum is used. X

Change made as stated.

28 Section 

4.2.1.3, 

page 4-6, 

line 18

Either delete “(figures)” or define which 

ones. X

Sentence revised to remove 

“(figures)”.

29 Section 

4.2.2.3, 

page 4-7, 

line 7

Define “walkover surveys”

X

The term “gross gamma 

radiation scan” is used 

starting in Section 3.1. The 

acronym GWS is used in 

Tables 3-3 and 3-4 headers 

and not defined in the 

acronyms list. The use of 

“Gamma radiation walkover 

surveys” in Section 4.2.2.3 

has been replaced with 

“Gross gamma radiation 

scans.” The rest of the 

document has been 

searched for consistent use 

of terms. The GWS 

acronym used in the 

headers for Tables 3-3 and 

3-4 has been changed to 

“Scan.”
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-22

COMMENTS BY REVIEWER

Reviewer: Number 4

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

30 Section 

5.3, page 

5-3, line 

37

Nice job of providing definition within the 

context of sentence! X

Noted.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-23

Peer Review – PA TENORM Study Report

COMMENTS BY REVIEWER

Reviewer: Number 5 

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

Appendix 

A

It seems to me some explanatory 

information is necessary. I suggest 

modifications as follows . . . X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

1 Page A-1, 

line 10

Change “geology” to “geologic”

X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

Page A-1, 

line 12

Insert the 3 paragraphs (or some other 

similar introduction) to help the reader get 

the gist of where this section is going. X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

Organic-rich, fine grained bodies of sediments have become the target of hydrocarbon production in 

Pennsylvania, and throughout the US, as a result of improved drilling and development methods, 

specifically horizontal drilling and hydraulic fracturing. As the chemical conditions which surrounded the 

deposition and subsequent diagenesis of these deposits have encouraged the deposition and concentration 

of naturally occurring radioactive materials, this section briefly describes some of the known, currently 

producing horizons, and likely to be explored/potentially produced that may result in the generation of 

technically enhanced NORM’s.

Although the focus of the TENORM Study is the solids and fluids resulting from hydrocarbon development, 

horizons rich in NORM occur at the surface, in areas where sediments outcrop as a result of natural 

features/events such as mountains, erosion, and manmade exposures such as mines, roadcuts, or 

foundation excavations.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-24

COMMENTS BY REVIEWER

Reviewer: Number 5 

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

The descriptions which follow are arranged in order from oldest to youngest age, geologically speaking. 

Although the expectation is the older horizons are deeply buried, geologic events (tectonics or “mountainbuilding”) have caused the horizons, in places, to occur at the surface as well as thousands of feet beneath 

the ground.

2 Page A-1, 

lines 13 –

34

Move to Page A-3, line 28. Seems this 

belongs under the Lockatong Formation 

section. X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

3 Page A-3, 

lines 8 –

10

Confusing? Not sure what is being said. 

Since Marcellus and Onondaga fluids will 

be in contact, they “will” be similar? Or 

there will be very little statistical similarity?

X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

4 Page A-3, 

line 12 & 

13

What is the point of the sentence? Is this 

meant to say poorly collection samples will 

be biased by oxidation? X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

5 Page A-3, 

lines 18 –

26

Need a date (?? MA) for this Burket 

Member X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

6 Page A-3, 

line 20

What does “inconspicuous” mean in this 

context? This, hard to find, not too limey? X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-25

COMMENTS BY REVIEWER

Reviewer: Number 5 

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

7 Page A-3, 

lines 23 & 

24

“To date, no volcanic . . .” Not sure why 

this is included. Has no bearing on the 

project UNLESS the ash beds are 

suspected source of NORM. If yes, more 

explanation is required.

X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

8 Page A-3, 

lines 42 –

44

Why is this mentioned? Seems out of 

context. X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

9 Page A-3,

line 27

Need an age for the Lockatong in ?MA

X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

10 Page A-4, 

line 2

Delete “obviously”

X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

11 Page A-4, 

line 7

“substantial hydraulic head” assumes the 

reader has a lot of background in fluid 

mechanics. Should be translated. The 

“suggestion” that the hot fluids passed 

rapidly to the surface is good.

X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

12 Page A-4, 

lines 21 & 

22

“ . . . but is unlikely to be . . .” While true, it 

does not belong here. X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-26

COMMENTS BY REVIEWER

Reviewer: Number 5 

Organization: Date:1/5/2015

RESOLUTION

Comment 

No.

Section / 

Page / Line 

No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

13 Page A-5, 

line 12

Define “ . . . was wasted.” Discarded? Not 

included in sample? X

This appendix was prepared 

by an external source and 

we chose not to edit that 

individual’s work.

14 Appendix 

A

A great read! Very informative.

X

Noted.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-27

Peer Review – PA TENORM Study Report

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

Gen-A This survey was well-designed, wellexecuted, and is very informative. It met 

the objectives stated in the plans. It is 

sufficiently broad in scope to capture the 

potential environmental insults. The 

results point to areas where more 

investigation and action is warranted.

Certain categories of 

facilities should be 

investigated further; 

despite being a very 

large survey, there is 

not enough statistical 

rigor in many instances 

to make actionable 

decisions. 

X

Noted.

Gen-B PA has a long history with radium 

contamination resulting from industrial 

activities. The PA DEP Bureau of 

Radiation Protection is one of the most 

experienced in the nation in dealing with 

these issues. 

X

Noted.

Gen-C The final report would have benefited 

from geospatial interpretation of the 

data, e.g., are the more radioactive 

residuals coming from one part of the 

play vs another or the wet gas side more 

than the dry side or visa versa. Are they 

evenly dispersed across the play? 

The report would 

benefit from the use of 

more graphics.

X

Noted. Report will be issued 

as is. The figures 

presenting survey data are 

in Appendix E.

Gen-D Consider parsing the data by facility in 

addition to study area. 

All pertinent 

information for a facility 

would then be in one 

appendix or table.

X

Noted. The individual survey 

maps, by facility, are in 

Appendix E.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-28

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

Gen-E Due to limited availability of some of the 

appendices and time constraints, this 

reviewer did not conduct full QC checks 

on any of the data sets. Cursory reviews 

indicate good QA and QC with good 

reporting and record keeping.

X

Noted.

Gen-F A review of the regulations and 

discharge permit parameters for facilities 

that handle, treat, and/or dispose of 

liquids from both conventional drilling 

and unconventional may be in order.

X

Noted. This is already 

identified as a 

recommendation for future 

action in Section 9.0 of the 

report.

Gen-G It is suggested that the report be issued 

as a draft.

Due to the volume of 

data and various ways 

it can be parsed, and 

the lack of geospatial 

interpretation, along 

with some needed 

resampling, it may be 

better to issue the 

report as a draft, and 

then issue a final report 

after comment 

resolution.

X

The peer review process 

was undertaken to have a 

group of subject matter 

experts review and comment 

upon the report prior to 

release. This report is a 

discrete representation of 

the efforts associated with 

this study including the 

observations and 

recommendations for future 

actions that can be made 

based on the analytical 

results obtained. 

Consequently, it isn’t 

necessary to issue this as a 

draft for comment. This 

report is viewed as an initial 
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-29

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

major effort in the collection 

of information necessary to 

effectively manage 

TENORM from O&G 

operations. Any future 

regulatory actions that would 

result from any data or 

recommendations

associated with this study 

will include an opportunity 

for public participation and 

comment.

Gen-H Consideration should be given to 

requiring Radiation Protection Plans, 

using a graded approach, as permit 

requirements for treatment facilities. 

These could include training 

requirements to address environmental 

and worker hazard, as well as required 

environmental and occupational 

monitoring. Facilities that generate highactivity radium wastes may be also 

candidates for a radioactive materials 

license.

X

Noted. Already included in 

recommendations for future 

actions in Section 9.0.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-30

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

Gen-I It should be noted (perhaps in a 

footnote) that 100 mrem/y is the 

accepted annual public dose limit for 

members of the public (there are other 

levels cited elsewhere). Note that value 

is considered the total dose from all 

activities combined (except medical 

procedures), so that one practice or 

entity should not be giving the entire 100 

mrem/y dose.

This metric was agreed 

to in the plans, so no 

change requested. 

Most estimates are 

very conservative and 

with few exceptions will 

any real workers 

receive a dose from 

TENORM that will 

approach the public 

dose limit.

X

Noted. The value is listed in 

Table 2-2 as a basis of 

comparison.

1

P4, s1.1 Typo Should be “Objectives” TOC XCorrected.

2 P5, S3.7 Typo Should be “Environmental” TOC XCorrected.

3

P5, S4.1 Typo Should be “Publicly” TOC

It seems that 

“Publically” is growing 

in popularity, but 

“Publicly” is what is 

used in RCRA.

X

Corrected.

4

P5, S4.27 Typo Should be “Environmental” TOC XCorrected.

5

P12 Typo Should be ± plus or “minus” Acronyms XCorrected.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-31

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

6

P12 Typo Should be POTW “Publicly” 

Owned Treatment Works

Acronyms XCorrected.

7

Introduction, 

P3, line1

Please List K-40 K-40 was analyzed in 

some samples, and is 

often the highest

concentration in the 

sample.

X

K-40 and all reported results 

along with standard error 

and MDC are presented in 

Appendix C.

8 Introduction, 

P3, line 7

The equilibrium may be, and often is 

disrupted by natural weathering and 

geochemistry, and of course radon 

emanation.

It is understood that in formation the 

uranium is not mobile, but that is not the 

case on the surface.

If it is not too much 

detail for this chapter, 

consider rephrasing 

the sentence to 

indicate that the 

radioactivity of surface 

soils is related to the 

natural radioactivity of 

the rocks the soil 

evolves from, as well 

as depletions of some 

isotopes due to 

weathering, chemical 

processes and 

emanation. .

X

Although correct, this level 

of detail is too much for this 

report.

9

Introduction, 

P3, line 10

Should be “ a Rn member” XCorrected.

10 Introduction, 

P1-3, line 10

While radon in gas may be an issue in 

some places as demonstrated in the 

report, the Pb-210 and Po-210 may be 

just as much of a concern.

Consider “Radon and 

its progeny are a 

concern ...uses.” X

Added “ and progeny.”
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-32

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

11 P1-5. Line 

20

It appears there is no direct mention of 

contaminated material and equipment, 

such as pipe, vessels, drill bits as a 

waste stream. If there were no 

measurements or evaluation of material 

and equipment, that should be noted.

These may be included 

in the facility 

evaluations, but 

hopefully can be 

mentioned in the 

introduction.

X

The study had limited 

access to pipe and 

equipment, specifically 

internal surfaces. This is 

already addressed in 

recommendations for future 

action in Section 9.0.

12 P1-5. Line 

45

It is this reviewers understanding that 

POTWs can only accept waters from 

conventional drilling.

If so, perhaps a 

footnote with that 

clarification could be 

considered. The reader 

should be aware of 

what the data 

represent. This is 

important since there 

are indications of 

radium contamination 

from conventional, 

insults from 

unconventional would 

be likely more severe.

X

This is already identified in 

Section 4.0 of the report.

13 P1-6, Line 

46.

Consider adding a sentence relative to 

the internals of the equipment can be 

contaminated with radon progeny.

X

Already addressed in 

Section 7.0
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-33

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

14 P2-9 Line 

14

Uranium can be, and is soluble in water 

depending on its ionic state.

Consider rewriting this 

sentence to reflect that 

the +4 ion is insoluble 

(predominant in the 

formation), but the +6 

ion (redox) is mobile. 

Are oxidizing agents 

used in making 

slickwater?

X

Although scientifically 

accurate, this was not 

observed in study.

15 P2-13, 

Table 2.2

In addition to Reg Guide 1.86, ANSI 

N13.12 has recently been updated and 

provides surface activity values that are 

more contemporary than 1.86 and are 

dose-based.

Consider listing ANSI 

N13.12 in addition to 

the 1974 Reg. Guide. X

Criteria listed are for 

benchmarking measurement 

results and not for 

compliance or use in 

assessments.

16 P2-13,

Table 2.2

ANSI N13.53 lists indoor, outdoor, 

occupational and residential exposure 

limits for radon

Consider adding ANSI 

N13.53 to the table

X

Criteria listed are for 

benchmarking measurement 

results and not for 

compliance or use in 

assessments.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-34

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

17 P3-1

Line 41 -

and the 

other worker 

scenario 

sections.

Areas surveyed for surface activity well 

represent potential exposure to most 

workers, and the surveys were robust. 

However, a review of the data sheets in 

Appendix D indicate that internals of pipe 

and equipment (e.g., in boneyards or 

maintenance shops) were not surveyed. 

It is the internals of pipe and equipment 

that would be most highly contaminated. 

Surveys show that no significant 

contamination was found on exposed 

surfaces.

Please consider 

strengthening the text 

in these paragraphs 

noting the purpose of 

the survey, and that 

based on the 

radionuclide content of 

the waters and gas, 

elevated alpha and 

beta activity are likely 

present on the 

internals of equipment 

that could pose a 

hazard to maintenance 

workers and recyclers.

X

Report already includes this 

as a recommendation for 

future action in Section 9.0.

18 P 3-10

Line 9

Consider follow up sampling and 

analysis to resolve the question.

See discussion in Appendix A.

It appears that the 

acidification of the 

unfiltered samples 

presents a potential 

issue. Since there is 

activity in both the 

filtered and unfiltered 

samples, the ratio 

between the two 

should be discerned 

somehow. Perhaps 

glass containers and 

no acidification until in 

the lab, if needed. Add 

X

Noted. The report already 

addresses this in the text 

and in Appendix I.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-35

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

this to the logistical 

challenges of sampling 

for Ra-224.

19 Tables If possible, measurement uncertainty 

should be reported, along with the MDC. 

Not reporting uncertainty makes some of 

the data less informative.

Would require 

landscape format. Can 

make a reference to 

the lab data in the 

Appendices for those 

parameters. For 

example, in many 

cases the gross alpha 

results are far below 

the Ra-226 results, 

which is unusual. 

Knowing the range of 

uncertainty on these 

measurements would 

be informative.

X

The standard errors 

(uncertainty) and the MDC 

values are already reported 

in Appendix C tables. This is 

noted in the report text.

20 Table 3-19 Without uncertainty being reported, it is 

difficult to fully appreciate these data.

See above

X

The standard errors 

(uncertainty) and the MDC 

values are already reported 

in Appendix C tables. This is 

noted in the report text.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-36

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

21 Page 4-2, 

Line 29

Were any other gamma emitters 

sampled? POTWs will often have manmade radioactivity in their influent from 

hospitals, etc.

I-131 can build up over 

time in POTWs and 

contribute to gamma 

exposure rates in the 

filter cake. Also exempt 

products such as 

smoke detectors can 

contribute to leachate 

concentrations. See 

the 2005 ISCORS 

reports.

X

An excellent point. Gamma 

spec reports for this study 

did not include anything but 

NORM radionuclides. 

22 P 4-7

Line 33

Appendix I was not available for review. XNoted.

23 P 4-21

Table 4-6

Typo. Change “35,4” to “35.4” XCorrected.

24 Page 4-22

Table 4.8 –

4.15

The MDCs for Ra-226 on many samples 

are quite high.

Perhaps would have 

benefited from longer 

counting times? When 

combined with the 

acidification question, 

these data for filtered 

samples may be 

uncertain, and are 

suggested for further 

study.

X

Noted. High MDCs are 

usually associated with high 

solid content in the liquid 

samples and is already 

discussed in the report.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-37

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

25 Page 4-27

Tables 4-14 

and 4-15

The radium results for influent at this 

non-impacted site seem high. If valid, 

historical industrial activities (e.g., 

mining) in the area should be evaluated 

to help determine why the influent is 

high.

The Ra-226 to gross 

alpha ratios for the 

filtered samples are 

seemingly incongruent. 

The unfiltered samples 

have too high a MDC 

to make a comparison.

X

Noted.

26 P 5-3

Sec. 5.3

This section is very informative. Was ingrowth 

considered when 

evaluating the truck 

drivers or plant 

workers, or was that 

just based on Ra-226? 

Some facilities will 

accumulate these 

residuals for some 

period of time prior to 

disposal.

X

Noted. Worker assessments 

were based on measured 

exposure rates. The truck 

driver assessment assumed 

Ra-226 in equilibrium with 

progeny, i.e., conservative if 

ingrowth has not been 

achieved.

27 P 5-5.

Figure 5-2

Figure is missing.

X

Figure 5-2, the sludge 

sample analytical results 

over time, is included.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-38

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

28 P 6-4

Line 1

Were there direct measurements made 

for alpha inside the housing or on the 

filter? Sampling the filter is 

representative of what remains in the 

stream of the gas, but may not represent 

what has plated out already on the 

internal surfaces.

The text only indicates 

that samples were 

collected and smears 

of the filter taken. Po210 is an obvious 

concern...

X

Access to internal housing 

or pipes was not available 

during the study. Additional 

surveys/samples when 

access is available is 

already a recommended 

future action in Section 9.0.

29 Ch 7

Line 4

These applications are from conventional 

wells. Elsewhere in the report it is stated: 

“...The Ra-226 activity in unconventional 

well site produced water is approximately 

20 times greater than that observed in 

conventional well site produced water.” 

Therefore, this evaluation may not be 

representative of unauthorized 

discharges from unconventional well 

sites, nor should it be used as 

justification for using fluids from 

unconventional wells on roads. 

Some of the 

background locations 

are elevated. There is 

no mention of what the 

NORM content of the 

gravel used in the 

roads may be. X

Noted. Unconventional brine 

application is prohibited in 

Pennsylvania.

30 Page 8-11

Table 8-2 –

Table 8.5

These data show the difficulty in getting 

representative data when sampling and 

analyzing field samples, particularly at 

low activity. While some of the isotopic 

data compare well, others fare less well. 

It is not clear why the samples are mixed 

well enough for some isotopes, but not 

others. 

Samples blended in 

the field just won't be 

as well mixed 

compared to drying, 

mixing and splitting in 

the lab. Much better 

chance of more 

homogeneous splits, 

though never perfect.

X

Noted. Blending liquid 

samples in not problematic 

but splitting solid samples is. 

The split sample results 

reflect this. Solid samples 

have been sent out for 

analysis in duplicate by the 

QC laboratory. However, the 

results are not currently 

available.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-39

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

31 P 9-10

Line 11

Please note that maintenance workers at 

midstream facilities can also be exposed 

to Pb-210 and Po-210 when working on 

internals of pipe and equipment. 

Progeny tend to plate 

out on surfaces where 

there is turbulence in 

the flow. That would 

include pumps, elbows, 

pig launchers/catchers, 

etc., in addition to the 

compressor stations 

themselves.

X

Noted. Section 7.0 already 

presents data and a 

recommendation for future 

action was made in 

Section 9.0.

32 P 9-10

Line 44

Other maintenance workers, such as 

workers in shop buildings are also at risk. 

Please expand the sentence to include 

all workers who could potentially be 

exposed.

X

Agree. The use of “worker” 

is generic, representing all 

workers including 

maintenance workers.

33 P 9-11

Line 28

Unfortunately, there are problems with 

these surveys and they should not be 

considered conclusive or representative.

See comment above 

and in conclusions 

section.

X

Noted.

34 P 9-12

Line 27

Agree All of these should be pursued, 

but with clarification:

Drill cuttings may take on the 

characteristics of the formation, and 

since fluids are recycled, the potential for 

cuttings to be contaminated is not trivial. 

Only cuttings that are below authorized 

limits should be candidates for release 

and reuse.

In addition to adding 

the isotopes to the 

analyte list, radiation 

survey equipment 

should be available 

within reasonable time 

frames to conduct 

routine surveys as part 

of spill response. 

Operators should be

trained on the use of 

these instruments.

X

Analysis for man-made 

radionuclides such as 

tracers used in O&G 

industry added as well as 

use of field survey 

instrumentation for areas 

impacted by spill.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-40

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

35 P 9-12

Line 34

Agree. All of these should be pursued. Consideration should 

be given to requiring 

Radiation Protection 

Plans, using a graded 

approach, as permit 

requirements for 

certain treatment 

facilities. These could 

include training 

requirements to 

address environmental 

and worker hazard, as 

well as required 

environmental and 

occupational 

monitoring. Facilities 

that generate highactivity radium wastes 

may be candidates for 

a radioactive materials 

license.

X

Noted. Section 9.2.2 

addresses.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-41

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

36 P 9-13

Line 1

Agree. All of these should be pursued. May also need to 

consider gw monitoring 

at some landfills. Basic 

training requirements 

and record keeping 

should be part of D&O 

plans or CD. Sampling 

suite should also 

include common 

isotopes from industry 

and medical institutions 

that can contribute to 

gross alpha and beta. 

Baseline samples 

recommended where 

possible before 

acceptance of 

residuals as there may 

well already be 

radioactivity in the 

leachate from other 

sources.

X

Noted. Recommendations 

for future action is included 

in Section 9.0.

37 P 9-13

Line 14

Agree. There is no analysis or 

accounting of Po-210. This could 

significantly underestimate risks to 

workers where there is Pb-210 

contamination.

This impacts the 

potential dose to some 

workers. Consider a 

statement about Po210.

X

Noted. Recommendation is 

already made in Section 9.0.
PA DEP TENORM Study Report – Appendix L Rev. 0

January 2015 L-42

COMMENTS BY REVIEWER

Reviewer: Number 6

Organization: Date:

RESOLUTION

Comment 

No.

Section / Page 

/ Line No.

Comment Other Details Accepted Accepted, but 

modified as 

follows

Rejected Reason for modification/rejection

38 It is the opinion of this reviewer that the 

alpha and beta contamination potential 

(and hazard) on well sites and 

compressor stations, gas plants, et al., is 

underestimated because there was no 

access to equipment internals. Also, Po210 does not appear to be considered, 

and that is an internal hazard.

Maintenance workers, 

on and off site (e.g., at 

repair shops) could be 

exposed to significant 

contamination based 

on years of experience 

in the industry.

X

Noted. Section 6.0 already 

discusses Po-210 and other 

alpha/beta emitting progeny 

of Rn and Section 9.0

recommends surveys of 

internal surfaces when 

accessible.

39 P 9-13

Line 21

Agree, as discussed elsewhere in the 

comments:

Since these applications are from 

conventional wells. Elsewhere in the 

report it is stated: “...The Ra-226 activity 

in unconventional well site produced 

water is approximately 20 times greater 

than that observed in conventional well 

site produced water.” Therefore, this 

evaluation may not be representative of 

unauthorized discharges from 

unconventional well sites, nor should it 

be used as justification for using fluids 

from unconventional wells on roads. 

Some of the 

background locations 

are elevated. There is 

no mention of what the 

NORM content of the 

gravel used in the 

roads may be. Further 

study recommended.

More sophisticated 

detectors (e.g., large 

area gas proportional 

or plastic scintillators, 

or much larger NaI 

crystals) will likely be 

required for analysis of 

these roads. 

Spectroscopy should 

also be used to strip 

out K-40, which will 

interfere with the 

measurements.

X

Noted. Only brine from 

conventional O&G 

production is permitted for 

application. Section 7.0

includes discussion of the 

high probability that 

reference background roads 

were also treated with brine, 

voiding true background 

measurements.