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Overview Report

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Marcellus Shale and Radioactivity
November 6, 2011 Submitted by; Dory Hippauf

Radioactivity (NORM - Naturally Occurring Radioactive Materials) exist in shale formations. When disturbed by human activity it becomes known as TENORM (Technologically Enhanced Naturally Occuring Radioactive Materials). TENORMS are found in the drill cuttings, returned Frackwater, Produced Brine, “recycled” frackwater, and the natural gas itself. Equipment, such as drills, drillbits and other equipment used over and over again to created gas wells may also become contaminated with radiation due to repeated exposure. Radiation has also been detected in water wells which have been contaminated by drilling activities. The following pages/documents give a more detailed overview.

Natural Gas Drilling Produces Radioactive Wastewater: Scientific...

http://www.scientificamerican.com/article.cfm?id=marcellus-shal...

Permanent Address: http://www.scientificamerican.com/article.cfm?id=marcellus-shale-natural-gas-drilling-radioactive-wastewater

Wastewater from natural gas drilling in New York State is radioactive, as high as 267 times the limit safe for discharge into the environment and thousands of times the limit safe for people to drink
By Abrahm Lustgarten and ProPublica | Monday, November 9, 2009 | 12 comments

As New York gears up for a massive expansion of gas drilling in the Marcellus Shale , state officials have made a potentially troubling discovery about the wastewater created by the process: It's radioactive. And they have yet to say how they'll deal with it. The information comes from New York State's Department of Environmental Conservation, which analyzed 13 samples of wastewater brought thousands of feet to the surface from drilling and found that they contain levels of radium 226, a derivative of uranium, as high as 267 times the limit safe for discharge into the environment and thousands of times the limit safe for people to drink. The findings, if backed up with more tests, have several implications: The energy industry would likely face stiffer regulations and expenses, and have more trouble finding treatment plants to accept its waste—if any would at all. Companies would need to license their waste handlers and test their workers for radioactive exposure, and possibly ship waste across the country. And the state would have to sort out how its laws for radioactive waste might apply to drilling and how the waste could impact water supplies and the environment. What is less clear is how the wastewater may affect the health of New Yorkers, since the danger depends on how much radiation people are exposed to and how they are exposed to it. Radium is known to cause bone, liver and breast cancers, and the EPA publishes exposure guidelines for it, but there is still disagreement over exactly how dangerous low-level doses can be to workers who handle it, or to the public. The DEC has yet to address any of these questions. But New York's Health Department raised concerns about the amount of radioactive materials in the wastewater in a confidential letter to the DEC's oil and gas regulators in July. "Handling and disposal of this wastewater could be a public health concern," DOH officials said in the letter, which was obtained by ProPublica. "The issues raised are not trivial, but are also not insurmountable." The letter warned that the state may have difficulty disposing of the drilling waste, that thorough testing will be needed at water treatment plants, and that workers may need to be monitored for radiation as much as they might be at nuclear facilities. Health Department officials declined to comment on the letter. The DEC sent an e-mail response to questions about the radioactivity stating that "concentrations are generally not a problem for water discharges, or in solid waste streams" in New York State. But the agency did not directly address the radioactivity levels, which were disclosed in the appendices of the agency's environmental review of gas drilling in the Marcellus Shale, released September 30. The review did not calculate how much radioactivity people may be exposed to, even though such calculations are routinely completed by scientists studying radiation exposure. Yet the review concluded that radiation levels were "very low" and that the wastewater "does not present a risk to workers." DEC officials declined to explain how they reached this conclusion. Although the review pointed to a possible need for radioactive licensing and disposal for certain materials, and it looked at other states with laws aimed at radioactive waste from drilling, the DEC said there is no precedent for examining how these radioactive materials might affect the environment when brought to the surface at the volumes and scale expected in New York. And it said that more study is needed before the DEC can lay out precise plans to deal with the waste.

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Natural Gas Drilling Produces Radioactive Wastewater: Scientific...

http://www.scientificamerican.com/article.cfm?id=marcellus-shal...

In comments to ProPublica, the DEC emphasized that the environmental review proposes testing all wastewater for radioactivity before it is allowed to leave the well site, and said that the volumes of brine water, which contain most of the radioactivity detected, would be far less than the volumes of fluid from hydraulic fracturing that are removed from the well. What scientists call naturally occurring radioactive materials—known by the acronym NORM—are common in oil and gas drilling waste, and especially in brine, the dirty water that has been soaking in the shale for centuries. Radium, a potent carcinogen, is among the most dangerous of these metals because it gives off radon gas, accumulates in plants and vegetables and takes 1,600 years to decay. Geologists say radioactivity levels can vary across the Marcellus, but the tests taken so far suggest the amount of radioactive material measured in New York is far higher than in many other places. The state took its 13 samples—11 of which significantly exceeded legal limits—between October 2008 and April 2009. The DEC did not respond to questions about whether additional sampling has begun or whether the state would begin issuing drilling permits before the radioactivity issues are resolved. The DEC told ProPublica it did not know where the wastewater would be treated. "It's got to go somewhere," said Theodore Adams, a radiation remediation and water treatment consultant with 30 years of experience with radioactive waste. "It's not going to just go away." A Vague Threat Determining the health threat that radioactive material poses to workers and to the public is complicated. Measuring human exposure —which is quantified in doses of millirems per year—from radiation is notoriously difficult, in part because it depends on variables like whether objects interfere with radiation, or how sustained exposure is over long periods of time. Gas industry workers, for example, would almost certainly face an increased risk of cancer if they worked in a confined space where radon gas, a leading cause of lung cancer and a derivative of radium, can collect to dangerous levels. They would also be at risk if they somehow swallowed or breathed fumes from the radioactive wastewater, or handled the concentrated materials regularly for 20 years. But without these types of intensive or confined exposures, the materials may be less dangerous, making it difficult to discern effects on workers' health, experts say. People absorb radioactivity in their daily routines, complicating health assessments. Eighty percent of human radioactivity exposure comes from natural sources, according to the EPA. Everything from granite countertops to a pile of playground dirt can emit radioactivity that is higher than the EPA, which regulates based on a theory that zero exposure is best, may prefer. "You start with the world where you and I are getting an exposure from the sun, from the soil we walk on, from the brick in our house that on average is about 400 millirems a year—which is dangerous," said Tom Lenhart, a former member of the federal-state Interagency Steering Committee on Radiation Standards. "The EPA would never allow that kind of exposure. So you are starting from a baseline of dangerous exposure, and this is what makes regulating it a nightmare." The EPA estimates that Americans are exposed to about 300 to 360 millirems per year, including routine artificial exposures like getting an x-ray or flying in an airplane. Each multiple of this "background level" denotes a proportional increase in the chance of getting cancer. The natural radioactivity of the Marcellus Shale has caused concern since the mid-1980s, when high levels of radon gas were found in the basements of homes in Marcellus, a town in upstate New York, where the shale reaches the surface. The question has long been, if the Marcellus can cause radioactive gas to seep into people's basements, how much radioactivity might be infused into the water left over from drilling? Add to that the question of how much human exposure can be expected from the radiation detected at some Marcellus drilling sites. In its environmental review, the state said it couldn't answer those questions because exposure depends on so many variables and because the units of measurement for human exposure and concentrations in water are incompatible. There is "no simple or universally accepted equivalence between these units," the DEC wrote in its environmental review. But Rick Kessy, operations manager for Fortuna Energy, a subsidiary of Canadian Talisman Energy and the largest gas producer in

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Natural Gas Drilling Produces Radioactive Wastewater: Scientific...

http://www.scientificamerican.com/article.cfm?id=marcellus-shal...

New York, says his company has assessed worker exposure at two of the company's well sites in Pennsylvania, where it found no serious risk. And a U.S. Department of Energy expert who specializes in such exposure conversions said an analysis in New York should be "very easy to do." "If they know the concentrations and they know the exposure pathways it should be straightforward to calculate that," said Charley Yu, who runs the national computer dose modeling program at http://www.talisman-energy.com/ for the U.S. Department of Energy. In fact, New York's DEC used Yu's government modeling program, called RESRAD, in a 1999 study to establish radioactivity exposure risks for oilfield brine spread on roads, a common disposal practice. Its brine samples in that case contained far less radium than the Marcellus water. It laid out a simple scenario, assuming a person walked on the road for two hours a day over 20 years and a fixed quantity of brine was spread there. That study found no threat to human health. No such analysis was included in the state's recent supplemental environmental impact statement. Few Disposal Options All this would be of substantially less concern if New York were like most of the other states that produce some radioactive waste during natural gas drilling. In those states, the waste is re-injected underground. But in New York, injection disposal wells are uncommon, and those that do exist aren't licensed to receive radioactive waste or Marcellus Shale wastewater, according to the EPA. Instead, most drilling wastewater is treated by municipal or industrial water treatment plants and discharged back into public waterways. The radium-laden wastewater would almost certainly need to be carefully treated by plants capable of filtering out the radioactive substances. Kessy, the Fortuna manager, which operates five of the wells with spiked readings in New York, said the levels are higher than he has seen elsewhere. Treatment plants in Pennsylvania are accepting Fortuna wastewater with much lower levels of radioactivity from the company's wells there, Kessy said, but if plants can't take the higher concentrations, it could be crippling. "In the event that they were not able to comply due to high radioactivity, they would reject the water," Kessy said. "And if we did not have a viable option for it, our operations would just shut down. There is no other option." It is not clear which treatment plants, if any in New York, are capable of handling such material. DEC spokesman Yancey Roy said that "there are currently no facilities specifically designated for treating them." He added that the state depends on the drilling companies to make sure there is a legal treatment option for the water, and then reviews those plans. "The department has not received any permit submissions from the well operators that include details about treatment options for the brine containing NORM," he said. "So we do not know what treatment options are being considered or how effective NORM removal will be." ProPublica contacted several plant managers in central New York who said they could not take the waste or were not familiar with state regulations. "We are not set up to take radioactive substances," said Patricia Pastella, commissioner of the Onondaga County Department of Water Environment Protection, which operates the Metropolitan plant in Syracuse, N.Y. "It does present a problem with disposal." Filtering the water is just one of several problems. Plants that can filter out the radioactive materials are left with a concentrated sludge that has substantially higher radioactivity than the wastewater. Sludge can also collect inside the pipes at well sites, in waste pits and in holding tanks. Federal laws don't directly address naturally occurring radioactivity, and the oil and gas industry is exempt from federal laws dictating handling of toxic waste, leaving the burden on New York State. New York has laws governing radioactive materials, but the state's

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Natural Gas Drilling Produces Radioactive Wastewater: Scientific...

http://www.scientificamerican.com/article.cfm?id=marcellus-shal...

drilling plans don't specify when they would apply. Experts who reviewed the concentrations of radioactive metals found in New York's wastewater said the leftover sludge is likely to exceed the legal limits for hazardous waste and would need to be shipped to Idaho or Washington State, to some of the only landfills in the country permitted to accept it. Fortuna's Kessy said that's an acceptable cost of doing business. "We'll be willing, of course, to fund the necessary disposal means," he said. The same may be required of some of the equipment used in drilling, which can eventually emit much higher levels of radiation than the water itself. Louisiana, for example, began regulating radioactive materials after it found radioactive buildup in pipes dumped in scrap yards and in the steel used to build schoolyard bleachers. But the levels in that state were just one eighth of those measured so far in New York. "I don't believe anyone has taken a look, seriously, at what the unintended consequences are to dealing with these kinds of materials," said Theodore Adams, the radioactive waste disposal consultant. "It's a unique animal—a unique disposal—and depending on where it is located and who is receiving it, it could have an impact." ProPublica's Sabrina Shankman contributed reporting to this article. Abrahm Lustgarten is an investigative reporter for ProPublica, an independent, nonprofit newsroom that produces journalism in the public interest.

Scientific American is a trademark of Scientific American, Inc., used with permission © 2011 Scientific American, a Division of Nature America, Inc. All Rights Reserved.

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Oil and Gas Production Wastes - EPA http://www.epa.gov/radiation/tenorm/oilandgas.html The geologic formations that contain oil and gas deposits also contain naturally-occurring radionuclides, which are referred to as "NORM" (Naturally-Occurring Radioactive Materials): uranium (and its decay products) thorium (and decay products) radium (and decay products) lead-210 Geologists have recognized their presence since the early 1930s and use it as a method for finding deposits (Ma87). Much of the petroleum in the earth's crust was created at the site of ancients seas by the decay of sea life. As a result, petroleum deposits often occur in aquifers containing brine (salt water). Radionuclides, along with other minerals that are dissolved in the brine, precipitate (separate and settle) out forming various wastes at the surface:     mineral scales inside pipes sludges contaminated equipment or components produced waters.

Because the extraction process concentrates the naturally occurring radionuclides and exposes them to the surface environment and human contact, these wastes are classified as TENORM. About TENORM (Technologically Enhanced Naturally-Occurring Radioactive Materials) http://www.epa.gov/radiation/tenorm/about.html TENORM is produced when radionuclides that occur naturally in ores, soils, water, or other natural materials are concentrated or exposed to the environment by activities, such as uranium mining or sewage treament. Radioactive materials can be classified under two broad headings:   man-made naturally occurring radioactive materials (NORM).

Why is EPA concerned about TENORM? Many of the materials that are technically TENORM have only trace amounts of radiation and are part of our everyday landscape. However, some TENORM has very high concentrations of radionuclides that can result in elevated exposures to radiation.

EPA is concerned about TENORM for three reasons.    It has the potential to cause elevated exposure to radiation. People may not be aware of TENORM materials and need information about them. Industries that generate these materials may need additional guidance to help manage and dispose of them in ways that protect people and the environment and are economically sound.

EPA is working to coordinate all of its TENORM efforts with other federal agencies, state and tribal governments, industry and public interest organizations. Coordinating our projects in this way will help us see the problem as a whole and will allow us to work together to develop solutions more effectively both within the Agency and with stakeholders outside the Agency

TENORM-Producing Industries EPA is studying TENORM-producing industries in the United States to learn which aspects of the problem, including health and environmental risks, are unique to a given industry and which are common across all industries. The results of these studies will appear as a series of reports on individual industries and will be provided on this web site as they become available. Each report will contain the following information:      generation of TENORM by the industry content of the material ways that people could be exposed to the industry's TENORM potential effects of exposure to materials from the industry how the industry handles or disposes of TENORM wastes.

Information on the following sources of TENORM is now available: http://www.epa.gov/radiation/tenorm/oilandgas.html     Mining Wastes Energy Production Wastes Water Treatment Wastes TENORM in Consumer Products

Waste Types and Amounts Each year the petroleum industry generates around 150,000 cubic meters (260,000 metric tons) of waste including produced water, scales, sludges, and contaminated equipment. The amount produced at any one oil reserve varies and depends on several factors:     geological location formation conditions type of production operation age of the production well.

An estimated 30 percent of domestic oil and gas wells produce some TENORM (McA88). In surveys of production wells in 13 states, the percent reporting high concentrations of radionuclides in the wells ranged from 90 percent in Mississippi to none or only a few in Colorado, South Dakota, and Wyoming (McA88). However, 20 to 100 percent of the facilities in every state reported some TENORM in heater/treaters.

Produced Waters The radioactivity levels in produced waters are generally low, but the volumes are large. The ratio of produced water to oil is approximately 10 barrels of produced water per barrel of oil. According to the American Petroleum Institute (API), more than 18 billion barrels of waste fluids from oil and gas production are generated annually in the United States. Produced waters contain levels of radium and its decay products that are concentrated, but the concentrations vary from site to site. In general, produced waters are re-injected into deep wells or are discharged into non-potable coastal waters.

Scale Scale is composed primarily of insoluble barium, calcium, and strontium compounds that precipitate from the produced water due to changes in temperature and pressure. Radium is chemically similar to these elements and as a result is incorporated into the scales. Concentrations of Radium-226 (Ra226) are generally higher than those of Ra-228. Scales are normally found on the inside of piping and tubing. The API found that the highest concentrations of radioactivity are in the scale in wellhead piping and in production piping near the wellhead. Concentrations were as high as tens of thousands of picocuries per gram. However, the largest volumes of scale occur in three areas:    water lines associated with separators, (separate gas from the oil and water) heater treaters (divide the oil and water phases) gas dehydrators, where scale deposits as thick as four inches may accumulate .

Chemical scale inhibitors may be applied to the piping complexes to prevent scales from slowing the oil extraction process. If the scales contain TENORM, the radiation will remain in solution and eventually be passed on to the produced waters. Approximately 100 tons of scale per oil well are generated annually in the United States. As the oil in a reservoir dwindles and more water is pumped out with the oil, the amount of scale increases. In some cases brine is introduced into the formation to enhance recovery; this also increases scale formation. The average radium concentration in scale has been estimated to be 480 pCi/g. It can be much higher (as high as 400,000 pCi/g) or lower depending on regional geology.

Sludge Sludge is composed of dissolved solids which precipitate from produced water as its temperature and pressure change. Sludge generally consists of oily, loose material often containing silica compounds, but may also contain large amounts of barium. Dried sludge, with a low oil content, looks and feels similar to soil. Oil production processes generate an estimated 230,000 MT or five million ft3 (141 cubic meters) of TENORM sludge each year. API has determined that most sludge settles out of the production stream and remains in the oil stock and water storage tanks. Like contaminated scale, sludge contains more Ra-226 than Ra-228. The average concentration of radium in sludges is estimated to be 75 pCi/g. This may vary considerably from site to site. Although the concentration of radiation is lower in sludges than in scales, sludges are more soluble and therefore more readily released to the environment. As a result they pose a higher risk of exposure. The concentration of lead-210 (Pb-210) is usually relatively low in hard scales but may be more than 27,000 pCi/g in lead deposits and sludge.   Contaminated Equipment Oil drilling rig.

TENORM contamination levels in equipment varied widely among types of equipment and geographic region. The geographic areas with the highest equipment readings were northern Texas and the gulf coast crescent from southern Louisiana and Mississippi to the Florida panhandle. Very low levels of TENORM were found in California, Utah, Wyoming, Colorado, and northern Kansas. According to an API industry-wide survey, approximately 64 percent of the gas producing equipment and 57 percent of the oil production equipment showed radioactivity at or near background levels. TENORM radioactivity levels tend to be highest in water handling equipment. Average exposure levels for this equipment were between 30 to 40 micro Roentgens per hour (μR/hr), which is about 5 times background. Gas processing equipment with the highest levels include the reflux pumps, propane pumps and tanks, other pumps, and product lines. Average radiation levels for this equipment as between 30 to 70 μR/hr. Exposures from some oil production and gas processing equipment exceeded 1 mR/hr. Gas plant processing equipment is generally contaminated on the surface by lead-210 (Pb-210). However, TENORM may also accumulate in gas plant equipment from radon (Rn-222) gas decay. Radon gas is highly mobile. It originates in underground formations and dissolves in the organic petroleum areas of the gas plant. It concentrates mainly in the more volatile propane and ethane fractions of the gas. Gas plant scales differ from oil production scales, typically consisting of radon decay products which accumulate on the interior surfaces of plant equipment. Radon itself decays quickly, (its half-life is 3.8 days). As a result, the only radionuclides that affect disposal are the radon decay products polonium210 (Po-210) and lead-210. Polonium-210 is an alpha emitter with a half-life of 140 days. Pb-210 is a weak beta and gamma emitter with a half-life of 22 years.

Disposal of Wastes When sludge fouling in water and oil storage tanks became a problem, the tanks were drained and the sludge disposed of in waste pits: Burn pits Earthen pits were previously used for temporary storage an periodic burning of non-hazardous oil field wastes collected from tanks and other equipment. Brine pits Lined and/or earthen pits were previously used for storing produced water and other nonhazardous oil field wastes, hydrocarbon storage brine, or mining wastes. In this case, TENORM in the water will concentrate in the bottom sludges or residual salts of the ponds. Thus, the pond sediments pose a potential radiological health risk. The radionuclides in these soils have been reported to be in the range from 270 to 1100 pCi/g.

Waste disposal The average concentration of the radium in the oil and gas wastes at offsite and onsite disposal facilities is approximately 120 pCi/g. Sludges containing elevated TENORM are now dewatered and held in storage tanks for later disposal. Produced waters are now generally reinjected into deep wells or, in the case of offshore production facilities, are discharged into non-potable coastal waters. No added radiological risks appear to be associated with this disposal method as long as the radioactive material carried by the produced water is returned in the same or lower concentration to the formations from which it was derived. As of 1992 there are 166,000 injection wells in 31 states. Pipes contaminated with scale are cleaned at pipe yards either by sandblasting them with high pressure water or by scraping out the scale with a rotating drill bit. The removed scale is then placed in drums and stored for later disposal. Contaminated equipment may either be cleaned and reused by the petroleum industry; disposed; or, if radiation levels are sufficiently reduced, sold for recycle. If equipment cannot be further decontaminated to acceptable levels, it is sent to a landfill licensed to accept NORM materials. In some cases contaminated steel may be reprocessed via smelting. During the smelting process molten steel separates from the NORM which vaporizes and is released as a gas. If the steel mill has pollution control equipment, most of the NORM is trapped in the baghouses and scrubbers. A typical smelting operation is capable of capturing 99 percent of the particulate releases.

NY Times on natural gas fracking: “The dangers to the environment and health are greater than previously understood.” By Joe Romm on Feb 27, 2011 at 4:50 pm Thinkprogess.org - excerpts http://thinkprogress.org/romm/2011/02/27/207596/natural-gas-fracking-dangers-environmenthealth/

While the existence of the toxic wastes has been reported, thousands of internal documents obtained by The New York Times from the Environmental Protection Agency, state regulators and drillers show that the dangers to the environment and health are greater than previously understood. The documents reveal that the wastewater, which is sometimes hauled to sewage plants not designed to treat it and then discharged into rivers that supply drinking water, contains radioactivity at levels higher than previously known, and far higher than the level that federal regulators say is safe for these treatment plants to handle. Other documents and interviews show that many E.P.A. scientists are alarmed, warning that the drilling waste is a threat to drinking water in Pennsylvania. Their concern is based partly on a 2009 study, never made public, written by an E.P.A. consultant who concluded that some sewage treatment plants were incapable of removing certain drilling waste contaminants and were probably violating the law. The Times also found never-reported studies by the E.P.A. and a confidential study by the drilling industry that all concluded that radioactivity in drilling waste cannot be fully diluted in rivers and other waterways. But the E.P.A. has not intervened. In fact, federal and state regulators are allowing most sewage treatment plants that accept drilling waste not to test for radioactivity. And most drinking-water intake plants downstream from those sewage treatment plants in Pennsylvania, with the blessing of regulators, have not tested for radioactivity since before 2006, even though the drilling boom began in 2008. In other words, there is no way of guaranteeing that the drinking water taken in by all these plants is safe.

NY Times Documents: Natural Gas's Toxic Waste 1. Over the past nine months, The Times reviewed more than 30,000 pages of documents obtained through open records requests of state and federal agencies and by visiting various regional offices that oversee drilling in Pennsylvania. Some of the documents were leaked by state or federal officials. Here, the most significant documents are made available with annotations from The Times. http://www.nytimes.com/interactive/2011/02/27/us/natural-gas-documents1.html#document/p417/a9945

2. This PowerPoint presentation, given by E.P.A. officials in 2009 to state and federal regulators in Pennsylvania, includes some of the results from an E.P.A study that tested whether certain rivers can sufficiently dilute radium-laced drilling wastewater. Such wastewater is passed through sewage treatment plants and discharged into the rivers; in their modeling, E.P.A. researchers looked at one plant where waste was being discharged into the Ohio River, a comparatively larger river that provides more dilution. They also studied another plant that discharged waste into the South Fork Tenmile River, which is smaller and thus provides less dilution. In both cases, the scientists found that the rivers would not dilute radium to allowable levels, according to this slideshow, as explained by an agency scientist familiar with the research. The radium levels considered in the agency’s modeling were also much lower than those found in The Times's review. E.P.A. officials said that the type of calculations done in their modeling of radium-laced waste discharged into rivers are actually something that the state is supposed to be doing as a standard step before they issue permits for sewage treatment plants to accept drilling wastewater. But the E.P.A. officials added that the state had not been doing all of these sorts of calculations for the range of contaminants, including the radioactive elements, in the wastewater. http://www.nytimes.com/interactive/2011/02/27/us/natural-gas-documents1.html#document/p533/a9948

New York State Water Resources Institute - Gas Wells - Waste

http://wri.eas.cornell.edu/gas_wells_waste.html

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Waste Management of Cuttings, Drilling Fluids, Hydrofrack Water and Produced Water
Cuttings and Drilling Fluids/Muds

When a well is drilled, the ‘cuttings’ of drilled rock need to be removed from the well bore. The cuttings, the drilling fluid or mud (to lubricate the drill and help remove the cuttings), and water in the bore hole are brought to the surface where the cuttings are then separated from the fluid, which will be reused in the drilling process. The cuttings and remaining fluids are generally stored in a drilling pit. In New York State, there are specifications regarding the construction of these pits, including a requirement that all pits be lined with plastic to avoid polluted water in the pit entering the soil and shallow groundwater. As mentioned in the Runoff section, it appears that the dSGEIS does not require that all drilling waste (including drilling muds, cuttings and flowback waters) be fully contained on site. Rather, drilling waste and possibly flowback waters can apparently be stored in open, lined pits on site except on floodplains and the NYC watershed. It is not clear why full containment should not be required for all sites. Drilling muds will be used in drilling in the Marcellus shale zone. According to the Oil and Gas Accountability Project, “drilling fluids or muds are made up of a base fluid (water, diesel or mineral oil, or a synthetic compound); weighting agents (most frequently barite is used); bentonite clay to help remove cuttings from the well and to form a filter cake on the walls of the hole; chrome lignosulfonates and lignites to keep the mud in a fluid state; and various additives that serve specific functions, such as biocides, diesel lubricants and chromate corrosion inhibitors….Drilling muds that circulate through the well and return to the surface may contain dissolved and suspended contaminants including cadmium, arsenic, and metals such as mercury, copper and lead; hydrocarbons; hydrogen sulfide and natural gas, as well as drilling mud additives, many of which contain potentially harmful chemicals (e.g., chromate, barite).” (http://www.earthworksaction.org/pubs/OGAPMarcellusShaleReport-6-12-08.pdf) Drill cuttings consist of a mixture of the different types of rocks through which the well is bored. As horizontal drilling will occur through the Marcellus shale, the cuttings from this shale will make up a reasonable portion of the total cuttings. These cuttings may be acidic and have the potential to mobilize metals in the cuttings or the soil to which they will be potentially exposed. Additionally, the Marcellus shale contains naturally occurring radioactive materials (NORMs), including radium. A 1999 investigation of NORMs in oil and gas wells found that the concentrations of NORMs on oil and gas production equipment and wastes pose no threat to the public health and the environment. (http://www.dec.ny.gov/docs/materials_minerals_pdf/normrpt.pdf). More recently, the DEC measured radiation from various Marcellus shale sources and concluded that NORMS “do not indicate an exposure concern for workers or the general public associate with Marcellus shale cuttings” (dSGEIS, 5-31).

Hydrofracking Fluids
Hydrofracking fluids are injected into wells under pressure in order to create cracks or fractures in the rock formation. These cracks accelerate gas flow out of the rock and into the well. Hydrofracking fluids are created by adding a proppant (commonly sand) to water. The role of the proppant is to keep the cracks from resealing once the hydrofracking fluid is withdrawn from the well. In addition to the proppant, several types of chemicals are added to the hydrofracking fluid to serve a number of purposes. A friction reducer is added to reduce the friction pressure during pumping operations. A surfactant is used to increase the recovery of injected water into a well. A biocide is used to inhibit the growth of organisms that could produce gases (particularly hydrogen sulfide) that could be dangerous as well as contaminate the methane gas. Scale inhibitors are used to control the precipitation of carbonates and sulfates. There is considerable controversy about the possible effects of the chemicals added to the hydrofracking fluids. On the one hand, the gas industry indicates that the chemicals they use are commonly used in other industries (see, for example, (http://www.fortunaenergy.com/upload/media_element /26/01/microsoft-word---chemical-descriptions-for-marcellus-shale-wells-fortuna-_2_.pdf) . On the other hand, included in the list in the dSGEIS of over 200 chemicals that may be used in hydrofracking are at least two known carcinogens: benzene and formaldehyde. For other compounds, such as xylene and to a lesser extent monoethanolamine, some information suggests carcinogenic activity, but the literature is not in agreement. Table 6-13 of the dSGEIS also lists heavy naptha as a material likely to be used. Heavy naptha is not a unique compound, but rather a mixture of many hydrocarbons, including several that are carcinogenic. Benzene is a high-risk carcinogen and was found in nearly half of all flowback waters (Table 5-9) from Pennsylvania and

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New York State Water Resources Institute - Gas Wells - Waste

http://wri.eas.cornell.edu/gas_wells_waste.html

West Virginia (14/29 samples) at concentrations ranging from 15.7 to 1950 µg/L, with an average of 479.5 µg/L. This average number is nearly 100 times the maximum contaminant level (5 µg/L) established by the EPA. The maximum concentration was nearly 400 times higher. Even if one considers a dilution or attenuation factor, as is done at superfund sites, of as much as 100, it is possible that mishandling of flowback water could contaminate nearby aquifers or groundwater at levels that could exceed a Maximum Contaminant Level (MCL) established by the EPA. Other compounds of concern in fracking fluids are nonylphenol and octylphenol ethoxylate surfactants which can be degraded by microbes to become endocrine disruptors that mimic estrogen and may adversely affect the health of terrestrial and aquatic wildlife. The ethoxylate portion of these compounds are easily removed by microbes and result in the formation of nonylphenol and octylphenol which are both weakly estrogenic. Normal monitoring of the parent compounds used in fracking fluids would not pick up the presence of these degradation products. Based on the similarity to other environmental exposure scenarios, it is reasonable to expect them to be present any time the parent surfactants are used in the environment. Exposure to these compounds, even at extremely low concentrations (µg/L) can cause feminization of fish. Requiring the use of less hazardous alternative compounds (aka substitution) is a well accepted method of risk mitigation. Many drilling companies phased out the use of benzene in the 1990s so it should be possible for those working in the Marcellus Shales to do the same. In order to reduce the risk of contamination associated with spills or storage failure, the use of benzene and other petroleum distillates in drilling fluids should be disallowed since functional alternatives exist. Alternative surfactants to nonylphenol and octylphenol ethoxylate exist so banning these compounds should not pose an undue burden on drilling companies.

Flowback
After hydrofracking, the hydrofracking fluid is withdrawn from the well, and to the extent possible, from the formation. Currently in Pennsylvania, about 15% of the hydrofracking fluid returns to the surface within 2 to 8 weeks (http://www.srbc.net/programs/docs/ProjectReviewMarcellusShale(NEW) (1_2010).pdf); this is referred to as flowback water. The rest of the water is presumably strongly absorbed by the shale and will only slowly return to the surface, primarily as water vapor, over the life of the gas well. The flowback water can be reused in hydrofracking other wells or disposed of as waste water. The Marcellus shale is of marine origin and naturally contains high levels of salt and NORMS, some of which will dissolve in the hydrofracking fluid and be brought to the surface in the flowback water. This waste water will likely contain high levels of total dissolved solids (mostly salt or sodium chloride) and NORMS, as well as added chemicals and/or their degradation products. There are three ways this water, now considered industrial waste water can be disposed: 1) underground injection, 2) municipal sewage treatment facilities (POTWs) that have an approved pretreatment program for industrial waste, and 3) private industrial waste treatment facilities. The sites available for underground injection of waste water are limited, and there are concerns that in certain locations underground injection may induce seismicity. POTWs must pretreat the waste water to the extent that the waste stream does not damage the sewage treatment system and does not exceed its permitted capacity to release pollutants to receiving waters. POTWs are generally not effective in removing salts from waste water, so there is concern that individual and cumulative releases to surface waters from treated, yet salt enriched, waste water could, from individual or cumulative releases, disrupt freshwater ecosystems. Currently, there are no private industrial waste treatment facilities for handling Marcellus shale flowback water in New York State. The issue of NORMS, primarily radium, in the flowback water needs to be considered as well. Radium in flowback water may be reduced during treatment to acceptable levels to discharge into surface waters through being retained in the solid waste. This raises the issue of where to dispose of the radium enriched solid waste from pre-treatment of flowback water or flowback water treated in private facilities. Both Louisiana and Texas regulate disposal of NORMS in solid waste from exploration and production of natural gas. It appears that NYS has this authority under NYCRR Part 360 (or 380 p7-102). However, reference is only made to standards for discharges in effluent; it is not clear whether standards exist for discharge in solid waste. A 1999 report prepared for the Department of Energy (Smith et al. 1999. An Assessment of the Disposal of Petroleum Industry NORM in nonhazardous Landfills, DOE/BC/W-31-109-ENG-38-8), considered the risks of disposing of NORMs in nonhazardous landfills. The study used a scenario of 2,000 cubic meters of solid waste with 50 picoCurries (pCi) per gram disposed in a landfill and found negligible harm to landfill workers, nearby residents, and future recreational users of the landfill property. It did note that higher levels could lead to increased risks. As shown in Appendix 13 of the dSGEIS, production brine from previously sampled wells drilled into the Marcellus Shale could have radium concentrations of upwards of 5000 pCi per liter. Assuming a pretreatment process removes solids that comprise 1% of the effluent volume including all the radium, this generates a solid with approximately 500 pCi per gram, 10 times the concentration used in the prior study. Although just a rough estimate, it highlights the potential for NORM levels above those even typically considered in other states when dealing with land disposal options.

Produced Water
As gas is pumped out of a well, water contained in the Marcellus shale formation may be withdrawn as well. This water is often called produced water. The volume of water produced is not expected to be great; one estimate is 42 gallons of water per million cubic feet (MMcf) of gas produced. At the end of the first year, a typical horizontal well in the Marcellus shale is not expected to produce more than 1 MMcf of gas per day; so produced water is not likely to exceed 300 gallons per week.

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Comments on Proposed DEC Regulations Marcellus Shale Development By Marvin Resnikoff, Ph.D. Radioactive Waste Management Associates October 2011
These comments on the proposed DEC regulations on Marcellus Shale Development pertain primarily to health and safety issues. Since the previous GEIS1, DEC has examined the regulatory experience in other states and responded to the concerns of New York City and State residents. The agency has done an excellent job in applying the experience of other States to New York. Nevertheless, the regulatory approach by DEC still needs major improvements and will not be protective of gas workers, the public and the environment. The author of these comments has had 20 years experience examining NORM in oil and gas exploration and production in Louisiana, Texas, Kentucky, Mississippi and more recently in New York State. As with our previous comments on the rdsgeis2, these comments do not directly pertain to the visual, noise or socioeconomic impacts of fracking General Comments in Support of Proposed Regulations The following sections of the proposed regulations are highly commendable and should be supported. Prior to drilling, DEC will require water well testing to establish a baseline. With this information, the State can know whether an aquifer has become contaminated, and can require cleanup to background. The State will also require information on nearby wells, including abandoned wells. This is important because increased pressure in the gas reservoir during fracking operations may lead to release of gas from nearby wells. DEC will also require a plan for disposal of flowback water and brine before drilling. This is important because flowback water and brine will be radiumcontaminated and must be properly disposed of. If flowback water and brine go to treatment plants, DEC will require SPDES permits for treatment plants and documentation of treatment plans before use, including monitoring requirements and testing at elap-certified labs.

Draft, Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program, Well Permit Issuance for Horizontal Drilling And High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and Other Low-Permeability Gas Reservoirs,” NYS Dept of Environmental Conservation, September 2009 2 Resnikoff, M, “Comments on rDSGEIS on Marcellus Shale Development,” Radioactive Waste Management Associates, October 2011.

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DEC will also require a listing of chemical additives to drilling fluids. Further, DEC will require specific well spacing between wells, with specific drilling depths and locations away from water supplies and aquifers. Before drilling within the Marcellus shale, DEC has specific requirements for blowout preventers including pressure testing. DEC also has specific detailed drilling and hydrofracturing requirements. Directional drilling cannot vary more than 5% from vertical depth; this is important to ensure that drills do not pierce the gas containment layer. Finally, DEC has specific requirements regarding the cementing of casings. Nevertheless, in our opinion the regulations do not go far enough in protecting water supplies and the health and safety of the general public, as we discuss below. Section 551.6 The owner of an oil, gas or solution mining , storage, stratigraphic, geothermal or disposal well that exceeds or that is expected to exceed 6,000 feet in true measured depth must file financial security for that well in an amount based upon the anticipated costs of plugging and abandoning that well to the satisfaction of the department in accordance with Part 555 of this Title[, up to $250,000. However, the owner is not required to file financial security under this section exceeding $2,000,000, regardless of the number of wells described in this section that the owner may have] It is commendable that DEC has changed this section to not place a dollar figure on plugging and abandoning a well. In addition to security for well plugging, DEC should require, if it has not done so in another section of the regulations, security or insurance for liability, to compensate the State and residents in case of a major accident or contamination of a water supply. In addition, Section 551.6 does not identify the form of security. This should be in the form of insurance or money placed in an escrow account overseen by the State. This should not be in the form of a security bond, which is only as good as the financial state of a company. In case of an extreme accident that tests the economic viability of a company, a security bond can be withdrawn by the issuing bank or company. Part 554, Drilling Practices and Reports Subdivision (c) of Section 554.1 (c)(1) Prior to the issuance of a [well-drilling] permit to drill, deepen, plug back or convert a well for any operation in which the probability exists that brine, salt water or other polluting fluids will be produced or obtained during such drilling operations or used to conduct such operations in sufficient quantities to be deleterious to the surrounding environment, the operator must submit and receive approval for a plan for the environmentally safe and proper ultimate disposal of such fluids. It is not clear from the GEIS what constitutes “environmentally safe…disposal of such fluids.” It is doubtful that standard water treatment plants will be satisfactory. Filter

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sludges are likely to become contaminated with radium, in which case DEC is just kicking the can down the road. Radium can be removed from flowback water; removal of radium is customarily done at uranium mills, but then the radium contaminated waste should be sent to Energy Solutions in Utah, or another location licensed to handle this radioactive waste. DEC should provide more specific guidance to the gas industry. DEC should also require that the aquifer be tested for concentrations of hydrocarbons, arsenic mercury, TDS and radium before well drilling commences, so that a baseline of background concentrations is known. In this way, DEC will know whether gas well drilling and production have contaminated an aquifer. (c)(4) Prior to the issuance of a permit to drill, deepen, plug back or convert a well, the operator must submit and receive approval for a plan for the environmentally safe and proper disposal or beneficial re-use of drill cuttings on-site or off-site. As DEC is aware, only a small percentage of drilling fluids and cuttings can be reused. 560.3 Application Requirements. In addition to the excellent list of requirements before gas drilling can commence, the Department should require testing of the aquifer for hydrocarbons, arsenic, mercury, TDS and radium, in an elap-certified laboratory. 560.5 Testing, Recordkeeping and Reporting Requirements (d) Water well testing (1) prior to well spud, the operator must make all reasonable attempts to sample and test residential water wells within 1,000 feet of the well pad for the parameters specified by the department. Before drilling, water well testing is important, in order to establish a baseline. This will allow DEC to know the impact of well drilling and gas production on the aquifer, particularly when gas wells are taken out of service. However, the department does not specify the parameters to be tested. This is open to lobbying by gas companies. At a minimum, the department should specify the parameters: hydrocarbons, arsenic, mercury, TDS and radium. Section 560.7 Waste Management & Reclamation (c) Cuttings contaminated with oil-based mud or polymer-based mud must be contained and managed in a closed-loop tank system and not be buried on site, and must be removed from the site for disposal in a solid waste disposal facility. Consultation with the department's Division of Materials Management (DMM) is required prior to disposal of any cuttings associated with water-based mud-drilling and pit liner associated with water-based mud-drilling where the water-based mud contains chemical additives. Any sampling and analysis directed by DMM must be by an ELAP-certified laboratory. All cuttings should be tested in an ELAP-certified laboratory, not just oil-based or polymer-based cuttings. Cuttings should be radium-tested according to EPA protocol, 903.0 or 903.1.

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(f) Flowback water recovered after high-volume hydraulic fracturing operations must be tested for naturally occurring radioactive material prior to removal from the site. Fluids recovered during the production phase (i.e., production brine) must be tested for naturally occurring radioactive material prior to removal. Flowback water should also be tested in an ELAP-certified laboratory, specifically for radium. Gamma testing for the surrogate Bi-214 should not be permitted. Radium concentrations are expected to be far higher than Bi-214 concentrations. (h) Partial reclamation and final reclamation of any well pad and access road must be approved by the department. In addition to flowback water and brine, DEC regulations should specify what will occur to production pipes, feed lines and condenser water tanks. In our experience, it is not unusual to remove production pipes after 5 years well production and these pipes will be internally coated with radium contaminated scale. The rdsgeis3 states that “NYSDOH will require the well operator to obtain a radioactive materials license when exposure rate measurements…exceed 50 microR/hr.” While this requirement exists in other States, the basis for this requirement is not clear. Further, the rdsgeis does not cite a specific section of NYSDOH regulation and we cannot locate one. Perhaps it is based on the fact that a worker works 2000 hours per year (50 wks x 40 hrs/wk), and this leads to a contact dose of 100 millirems/year, the allowable dose to a member of the public. In any case, this NYSDOH limit, 50 microR/hr, is unacceptable and hydrofracturing of the Marcellus shale formation should not proceed until this matter is resolved. Aside from tossing the ball to NYSDOH, the basic issue is, what will become of radium-contaminated pipes? In our experience with gas pipes in Texas, after 5 years production, more than 50% of the pipes will have direct gamma rates greater than 50 microR/hr. According to our calculations using Microshield, and a standard 3 to 1 ratio of radium-226 to radium-228, pipes that emit gamma equal to 50 microR/hr will have radium-226 and radium-228 concentrations in scale that exceed 1300 pCi/g and 400 pCi/g, respectively. If these pipes are released for general unrestricted use, they can be used for corrals, playground equipment, etc. If radium at these concentrations are released to the environment, the respective radiation doses to children and the general public will be high; neither NYSDOH nor NYSDEC has produced an EIS that evaluates the impact to individuals and general society of releasing contaminated pipes for general use. 750-3.4 Requirement to obtain a permit (b)(1) Documentation from a legally permissible disposal facility that available capacity exists for the disposal of the projected amount of flowback fluid and production brine over the life of the well, and/or identification and certification of available capacity for alternative disposal locations; In our opinion, it is possible to remove radium from flowback water and production brine at specialized facilities, and licensed facilities exist to accept radium filters and sludges.
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Rdgeis, p. 5-142 and p. 6-205.

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750-3.11 Applications of standards, limitations and other requirements (h)(i) Flowback water recovered after high-volume hydraulic fracturing operations must be tested for NORM prior to removal from the site. Fluids recovered during the Production Phase (i.e., production brine) must be tested for NORM prior to removal, and the ground adjacent to the tanks must be measured for radioactivity. All testing must be in accordance with protocols satisfactory to the New York State Department of Health. Flowback water should be tested in an ELAP-certified laboratory, specifically for radium, according to EPA protocols 903.0 or 903.1. Gamma testing for the surrogate Bi-214 should not be permitted. Additional Permit Requirements Production Pipes, Separators, Feed Lines and Water Condenser Tanks As the Department is aware, radium-contaminated scale will form in production pipes, separators, feed lines and water condenser tanks during production of natural gas. Depending on a conditions, production pipes may become occluded and have to be removed and replaced. We have seen conditions where production pipes have been removed as early as five years after initial production. Of 368 pipes from a single well in Texas tested for direct gamma, 204 pipes had direct gamma readings greater than 50 µR/h and 139 had direct gamma readings less than 50 µR/h. Twenty-five pipes contained no NORM. The highest reading was 150 µR/h. According to the rdsgeis, NYSDOH will require a materials license if pipes emit gamma radiation >50 µR/h. However, we cannot locate this licensing condition in NYSDOH regulations. Since flowback water and brine are expected to have high radium concentrations, a radioactive materials license should be required at the point an operator is drilling in the Marcellus shale formation. This license should be continued during production and decommissioning phase. Based on our experience, a majority of production pipes are expected to have gamma rates >50 µR/h; these pipes would then be automatically covered under the NYSDOH license. The basis for the licensing requirement for production pipes with gamma rates >50 µR/h is unclear, other than the fact that this is a requirement in several states. In order for gamma rates to exceed 50 µR/h, the Ra-226 and Ra-228 concentrations of radium must be greater than 1300 pCi/g and 400 pCi/g, respectively. If pipes emitting 50 µR/h are released for unrestricted use, they can be used for any non-licensed purpose. They can be cut up and used in playgrounds for children. Ra-226 at concentrations exceeding 1300 pCi/g can be strewn on the ground. The direct gamma rates would then greatly exceed 50 µR/h. This regulatory scheme makes no sense. Further, the environmental impact of disposal of production pipes, feed lines, separators and condenser tanks should also be under SEQRA review and an EIS should be prepared by NYSDOH.