Update on ODOE Notice of Violation for “TENORM” Disposal at Arlington Landfill

In February 2020, the Oregon Department of Energy issued a Notice of Violation for disposal of radioactive materials in violation of state law at the Chemical Waste Management landfill in Arlington, Oregon. The waste is known as TENORM – technologically enhanced naturally occurring radioactive materials, in this case from the oil and gas industry. After being alerted by ODOE, the landfill operator immediately stopped receiving the waste, and ODOE, in consultation with the Oregon Health Authority’s Radiation Protection Services, determined there was no current threat to landfill workers, the public, or the environment.

With the violation, ODOE is requiring Chemical Waste Management to complete a corrective action plan and detailed risk assessment. At the time of the violation, ODOE shared that we expected to receive those documents in late April. However, CWM determined that completing the requested documents would take more time, and asked for an extension to submit the documents by September 1, 2020. ODOE granted the extension, but required CWM to submit some preliminary documents by April 30.

The preliminary documents are now available on ODOE’s website, including:

  • An annotated outline of the dose and Risk Assessment report under development, including a description of the purpose of each document section and any key methods of analysis.

  • An annotated outline of the Corrective Action Plan under development, including a description of the purpose of each document section and any key methods of analysis.

  • A detailed evaluation of past and present worker doses and risks during the waste disposals. 

  • A location-specific map and description of all subject wastes within the specific disposal cell, along with a series of two-dimensional slices communicating key waste locations.

  • A site-specific discussion of the geology and hydrogeology of the impacted cell at the Chemical Waste Management Arlington facility and the potential for future migration of radionuclides to underlying groundwater resources or surface waters in the vicinity of the site.

  • An explanation of the survey plan for the specific disposal cell and for characterizing the radiological background of the area.

ODOE will continue to provide updates and will notify the public when the final documents have been submitted in September. The documents will help determine what to do with the waste already in the landfill (if it should be removed or remain in place). ODOE will also review the Corrective Action Plan to assess if the actions the landfill is proposing will prevent this from happening again.

There will be an opportunity for public review and comment this fall. For the latest updates, bookmark ODOE’s website or sign up for email updates.