shale gas radiation

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Overview Report:

Marcellus Shale and RadioactivityNovember 6, 2011 Submitted by; Dory Hippauf


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Radioactivity (NORM - Naturally Occurring Radioactive Materials) exist in shale forma-

tions. When disturbed by human activity it becomes known as TENORM (Technologi-

cally Enhanced Naturally Occuring Radioactive Materials).

TENORMS are found in the drill cuttings, returned Frackwater, Produced Brine, re-cycled 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 con-

taminated with radiation due to repeated exposure.

Radiation has also been detected in water wells which have been contaminated bydrilling activities.

The following pages/documents give a more detailed overview.


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As New York gears up for a massive expansion of gas drilling in the , 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 l imit 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 wasteif 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

publ ishes 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 reviewof 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.

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

Marcellus Shale

ral Gas Drilling Produces Radioactive Wastewater: Scientific... http://www.scientificamerican.com/article.cfm?id=marcellu

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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 materialsknown by the acronym NORMare 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 samples11 of which significantly exceeded legal limitsbetween 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 yearfrom 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 yearwhich 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 inthe 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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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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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 l ikely to

exceed the legal limits for hazardous waste and would need to be shipped to Idaho or Washington State, to some of the only landfil ls

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 animala unique disposaland 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 forProPublica, 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 - EPAhttp://www.epa.gov/radiation/tenorm/oilandgas.html

The geologic formations that contain oil and gas deposits also contain naturally-occurringradionuclides, 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 forfinding deposits (Ma87).

Much of the petroleum in the earth's crust was created at the site of ancients seas by the decay ofsea 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 andsettle) 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 themto 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 naturalmaterials are concentrated or exposed to the environment by activities, such as uranium mining orsewage 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 partof our everyday landscape. However, some TENORM has very high concentrations of radionuclidesthat can result in elevated exposures to radiation.


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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 anddispose 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 tribalgovernments, industry and public interest organizations. Coordinating our projects in this way will helpus see the problem as a whole and will allow us to work together to develop solutions more effectivelyboth within the Agency and with stakeholders outside the Agency

TENORM-Producing IndustriesEPA is studying TENORM-producing industries in the United States to learn which aspects of theproblem, including health and environmental risks, are unique to a given industry and which arecommon across all industries. The results of these studies will appear as a series of reports onindividual industries and will be provided on this web site as they become available. Each report willcontain 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 AmountsEach year the petroleum industry generates around 150,000 cubic meters (260,000 metric tons) ofwaste 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.


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An estimated 30 percent of domestic oil and gas wells produce some TENORM (McA88). In surveysof production wells in 13 states, the percent reporting high concentrations of radionuclides in the wellsranged 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 inheater/treaters.

Produced WatersThe radioactivity levels in produced waters are generally low, but the volumes are large. The ratio ofproduced 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 gasproduction are generated annually in the United States.

Produced waters contain levels of radium and its decay products that are concentrated, but theconcentrations vary from site to site. In general, produced waters are re-injected into deep wells orare discharged into non-potable coastal waters.

ScaleScale is composed primarily of insoluble barium, calcium, and strontium compounds that precipitatefrom the produced water due to changes in temperature and pressure. Radium is chemically similarto these elements and as a result is incorporated into the scales. Concentrations of Radium-226 (Ra-226) are generally higher than those of Ra-228.

Scales are normally found on the inside of piping and tubing. The API found that the highestconcentrations of radioactivity are in the scale in wellhead piping and in production piping near thewellhead. Concentrations were as high as tens of thousands of picocuries per gram. However, thelargest 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 theoil extraction process. If the scales contain TENORM, the radiation will remain in solution andeventually 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 ina reservoir dwindles and more water is pumped out with the oil, the amount of scale increases. Insome 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 muchhigher (as high as 400,000 pCi/g) or lower depending on regional geology.


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SludgeSludge is composed of dissolved solids which precipitate from produced water as its temperature andpressure 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 feelssimilar to soil.

Oil production processes generate an estimated 230,000 MT or five million ft3 (141 cubic meters) ofTENORM sludge each year. API has determined that most sludge settles out of the productionstream and remains in the oil stock and water storage tanks.

Like contaminated scale, sludge contains more Ra-226 than Ra-228. The average concentration ofradium in sludges is estimated to be 75 pCi/g. This may vary considerably from site to site. Althoughthe concentration of radiation is lower in sludges than in scales, sludges are more soluble andtherefore 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 than27,000 pCi/g in lead deposits and sludge.

Contaminated Equipment

Oil drilling rig.

TENORM contamination levels in equipment varied widely among types of equipment and geographicregion. The geographic areas with the highest equipment readings were northern Texas and the gulfcoast crescent from southern Louisiana and Mississippi to the Florida panhandle. Very low levels ofTENORM were found in California, Utah, Wyoming, Colorado, and northern Kansas.

According to an API industry-wide survey, approximately 64 percent of the gas producing equipmentand 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 exposurelevels for this equipment were between 30 to 40 micro Roentgens per hour (R/hr), which is about 5times 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 thisequipment as between 30 to 70 R/hr. Exposures from some oil production and gas processingequipment 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 organicpetroleum areas of the gas plant. It concentrates mainly in the more volatile propane and ethanefractions of the gas.

Gas plant scales differ from oil production scales, typically consisting of radon decay products whichaccumulate on the interior surfaces of plant equipment. Radon itself decays quickly, (its half-life is 3.8days). As a result, the only radionuclides that affect disposal are the radon decay products polonium-210 (Po-210) and lead-210. Polonium-210 is an alpha emitter with a half-life of 140 days. Pb-210 is aweak beta and gamma emitter with a half-life of 22 years.


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Disposal of WastesWhen sludge fouling in water and oil storage tanks became a problem, the tanks were drained andthe sludge disposed of in waste pits:

Burn pitsEarthen pits were previously used for temporary storage an periodic burning of non-hazardous oil

field wastes collected from tanks and other equipment.

Brine pitsLined 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 willconcentrate in the bottom sludges or residual salts of the ponds. Thus, the pond sediments pose apotential radiological health risk. The radionuclides in these soils have been reported to be in therange from 270 to 1100 pCi/g.

Waste disposalThe 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 laterdisposal.

Produced waters are now generally reinjected into deep wells or, in the case of offshore productionfacilities, are discharged into non-potable coastal waters. No added radiological risks appear to beassociated with this disposal method as long as the radioactive material carried by the producedwater is returned in the same or lower concentration to the formations from which it was derived. Asof 1992 there are 166,000 injection wells in 31 states.

Pipes contaminated with scale are cleaned at pipe yards either by sandblasting them with highpressure water or by scraping out the scale with a rotating drill bit. The removed scale is then placedin 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 furtherdecontaminated 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 processmolten steel separates from the NORM which vaporizes and is released as a gas. If the steel mill haspollution 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.


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NY Times on natural gas fracking: The dangers to the environment and health are greaterthan previously understood.By Joe Romm on Feb 27, 2011 at 4:50 pmThinkprogess.org - excerptshttp://thinkprogress.org/romm/2011/02/27/207596/natural-gas-fracking-dangers-environment-health/

While the existence of the toxic wastes has been reported, thousands of internal documents obtainedby The New York Times from the Environmental Protection Agency, state regulators and drillers showthat 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 notdesigned to treat it and then discharged into rivers that supply drinking water, containsradioactivity at levels higher than previously known, and far higher than the level that federalregulators 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 2009study, never made public, written by an E.P.A. consultant who concluded that some sewagetreatment plants were incapable of removing certain drilling waste contaminants and were probablyviolating the law.

The Times also found never-reported studies by the E.P.A. and a confidential study by thedrilling industry that all concluded that radioactivity in drilling waste cannot be fully diluted inrivers and other waterways.

But the E.P.A. has not intervened. In fact, federal and state regulators are allowing most sewagetreatment 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 ofregulators, have not tested for radioactivity since before 2006, even though the drilling boom began in2008.

In other words, there is no way of guaranteeing that the drinking water taken in by all these plants issafe.


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NY Times Documents: Natural Gas's Toxic Waste1. Over the past nine months, The Times reviewed more than 30,000 pages of documents obtainedthrough open records requests of state and federal agencies and by visiting various regional officesthat 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-documents-1.html#document/p417/a9945

2. This PowerPoint presentation, given by E.P.A. officials in 2009 to state and federal regulators inPennsylvania, includes some of the results from an E.P.A study that tested whether certain rivers cansufficiently dilute radium-laced drilling wastewater. Such wastewater is passed through sewagetreatment plants and discharged into the rivers; in their modeling, E.P.A. researchers looked at oneplant where waste was being discharged into the Ohio River, a comparatively larger river thatprovides more dilution. They also studied another plant that discharged waste into the South ForkTenmile River, which is smaller and thus provides less dilution. In both cases, the scientists foundthat the rivers would not dilute radium to allowable levels, according to this slideshow, as explainedby an agency scientist familiar with the research. The radium levels considered in the agencys

modeling were also much lower than those found in The Times's review. E.P.A. officials said thatthe type of calculations done in their modeling of radium-laced waste discharged into riversare actually something that the state is supposed to be doing as a standard step before theyissue 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 rangeof contaminants, including the radioactive elements, in the wastewater.http://www.nytimes.com/interactive/2011/02/27/us/natural-gas-documents-1.html#document/p533/a9948


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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

H O ME A B O U T U S G R A N TS C O LLA B O R A TIO N S TA FF P E O P LE B L O G S U B S C R IB E

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West Virginia (14/29 samples) at concentrations ranging from 15.7 to 1950 g/L, with an average of 479.5 g/L. This average number is nearly 100 times

the maximum contaminant level (5 g/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 thesecompounds, even at extremely low concentrations (g/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

ByMarvin 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 theconcerns 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 gasworkers, 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 abaseline. With this information, the State can know whether an aquifer has becomecontaminated, 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 ofgas 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 radium-

contaminated and must be properly disposed of. If flowback water and brine go totreatment 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.

1 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 20092 Resnikoff, M, Comments on rDSGEIS on Marcellus Shale Development, Radioactive Waste

Management Associates, October 2011.


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Comments on Proposed Regs on Gas Drilling Page 2


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 locationsaway from water supplies and aquifers.

Before drilling within the Marcellus shale, DEC has specific requirements for blowoutpreventers 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 containmentlayer. 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 ordisposal well that exceeds or that is expected to exceed 6,000 feet in true measured depthmust file financial security for that well in an amount based upon the anticipated costs ofplugging and abandoning that well to the satisfaction of the department in accordancewith Part 555 of this Title[, up to $250,000. However, the owner is not required to filefinancial security under this section exceeding $2,000,000, regardless of the number ofwells 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 orcontamination of a water supply. In addition, Section 551.6 does not identify the form ofsecurity. 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 theeconomic 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 orconvert a well for any operation in which the probability exists that brine, salt water orother polluting fluids will be produced or obtained during such drilling operations orused to conduct such operations in sufficient quantities to be deleterious to thesurrounding environment, the operator must submit and receive approval for a plan forthe environmentally safe and proper ultimate disposal of such fluids.It is not clear from the GEIS what constitutes environmentally safedisposal of suchfluids. 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; removalof 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 thisradioactive waste. DEC should provide more specific guidance to the gas industry. DECshould 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 welldrilling and production have contaminated an aquifer.

(c)(4) Prior to the issuance of a permit to drill, deepen, plug back or convert a well, theoperator must submit and receive approval for a plan for the environmentally safe andproper 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, theDepartment 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 testresidential 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 willallow 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 aminimum, 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 containedand 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 thedepartment's Division of Materials Management (DMM) is required prior to disposal ofany cuttings associated with water-based mud-drilling and pit liner associated withwater-based mud-drilling where the water-based mud contains chemical additives. Anysampling 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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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 theProduction Phase (i.e., production brine) must be tested for NORM prior to removal, andthe ground adjacent to the tanks must be measured for radioactivity. All testing must bein 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 inTexas tested for direct gamma, 204 pipes had direct gamma readings greater than 50 R/h

and 139 had direct gamma readings less than 50 R/h. Twenty-five pipes contained no

NORM. The highest reading was 150 R/h.

According to the rdsgeis, NYSDOH will require a materials license if pipes emit gamma

radiation >50 R/h. However, we cannot locate this licensing condition in NYSDOH

regulations.

Since flowback water and brine are expected to have high radium concentrations, aradioactive 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 areexpected to have gamma rates >50 R/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 R/h

is unclear, other than the fact that this is a requirement in several states. In order for

gamma rates to exceed 50 R/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 R/h arereleased 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 50R/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.