After a piece of radioactive pipe from Ashland Oil’s Martha oil field tripped a Geiger counter at a scrap yard in 1988, Ashland August 11, 2005 letter to the Kentucky Department for Public Health:
The discovery of elevated levels of radioactivity in the Martha oil field in the late 1980’s led to the development of a “Joint Agreement on Martha Reclamation Program (MRP)” executed between the Cabinet for Human Resources (CHR) and Ashland Exploration (AEI), in which AEI agreed to a program of reclamation under a document captioned “Martha Reclamation program” (August 1, 1993), modified by Technical Support Addendum (October/December 1994) and Technical Consensus Document (January 1995) in which levels of NORM would be lowered through selective removal of contaminated media, to agreed-upon values for radioactivity, with confirmatory sampling by the company and oversight by the Cabinet. The exemption criteria below which no remediation would be required was set at 5 pCi/gm above natural background and averaged over 100 square meters, in the top 15 cm of soil (with 15 pCi below 15 cm).
Whew! Reading that was about as fun as clearing kudzu. We think what he meant was Ashland and the state of Kentucky entered into an agreement to clean up the radiation to an agreed standard, with testing performed by Ashland (overseen by the state of Kentucky) to confirm that the agreed standard was met. Now, back to Mr. FitzGerald…
After execution of the Joint Agreement in February 1995, procedures were agreed upon by CHR and AEI for selective confirmatory surveys of well sites and tank battery sites, for removal of contaminated soil and piping to a local collection and storage site, and for securing letters from CHR approving the remediated sites for “unrestricted release.” The “First Addendum to Joint Agreement on Martha Reclamation Program” executed in September 1995, contained procedures for release of sites, allowing any site with a reading below 20 micro r/hr at 1 meter above ground to be released, and providing for confirmatory surveys of a statistical sampling of the remediated sites. Over a period of several years as reclamation work was being undertaken by OHM under contract with AEI, data was submitted to the state concerning sites that had been “remediated” and letters of concurrence from CHR of the eligibility of many properties for unrestricted release were issued. The soils and piping removed by AEI were stored on AEI property, and to this day, significant quantities of the NORM-contaminated soil remain at a consolidation site and have not been properly disposed of in a permanent disposal site.
In other words, a process was put in place to survey selected sites where radioactive waste was likely to be, and the radioactive pipes, sludge, scale, soils, etc. that exceeded an agreed measurement threshold were removed to a temporary consolidation site on
…Data developed on the Martha oil field through field surveys conducted by the Cabinet for Human Resources and the Natural Resources and Environmental Protection Cabinet, as well as a consultant for an oil company in the area, indicates the existence of numerous sites where levels of radium-226 has been detected at excessive levels. These areas include apparently dozens of brine/sludge pits in the Martha oil field that were formerly used for separation of oil and produced water (brine), and for disposal of oil-related sludges and clays as well as other land areas which currently or formerly supported tank batteries (oil/water separators) or piping and equipment storage, many of which exhibit levels of radium-226 as much as hundreds of times above the levels deemed unacceptable due to health consequences by the United States Environmental Protection Agency for human exposure.
So, even though we’ve all been through the Martha Reclamation Program for the past 15 years we still have hazardous radioactive hot spots throughout the oil field. So the clean-up has not been successful. And we have a temporary radioactive waste dump site that is starting to look permanent. We have radioactive waste drained out of old storage tanks, dumped into holes and buried. Some of these remediation efforts remind us of when we try to get our teenage kids to clean their rooms; at first things look OK but then we find that all the dirty socks and underwear end up under the bed.
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