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Landfill disposal of drill cuttings

Landfill Disposal of WV Oil and Gas Waste – A Report Review

By Bill Hughes, WV Community Liaison

As oil and gas drilling increases in West Virginia, the resulting waste stream must also be managed. House Bill 107 required the Secretary of the West Virginia Department of Environmental Protection to investigate the risks associated with landfill disposal of solid drilling waste. On July 1, 2015, a massive report was issued that details the investigation and its results: Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

While I must commend the State for looking into this important issue, much more needs to be done, and I have serious concerns about the validity of several aspects of this study. Since the report is almost 200 pages long, I will summarize its findings and my critiques below.

Summary of Waste Disposal Concerns in Report

The page numbers that I reference below refer to the page numbers found within the PDF version of the full study.

  1. Marcellus shale cuttings are radioactive: pgs. 17, 139, 142, 154
  2. We do not know if there is a long term problem: pg. 19
  3. About 30 million tons of waste in next few decades: pg. 176
  4. Landfill liners leak: pg. 20
  5. Owning & operating their own landfill would be expensive & risky for gas companies: pgs. 186-7
  6. Toxicity and biotic risk from drill cuttings is uncharted territory: pg. 78
  7. Landfill leachate is toxic to plants & invertebrates: pgs. 16, 95, 97
  8. Other landfills also have radioactive waste: pgs. 14-15
  9. We have no idea if this will get worse: pgs. 96, 154
  10. If all systems at landfills work as designed, leachate might not affect ground water: pg. 41

Introduction

WV Field Visits 2013

Drilling rig behind a wastewater pond in West Virginia

Any formal report comprised of 195 pages generated by a reputable school like Marshall University with additional input from Glenville State College – supported by over 2,300 pages of semi-raw data and graphs and charts and tables – requires some serious investigation prior to making comprehensive and final conclusions. However, some initial observations are needed to provide independent perspective and to help reflect on how sections of this report might be interpreted.

The overarching perspective that must be kept in mind is that the complete study was first limited by exactly what the legislature told the WV Department of Environmental Protection DEP to do. Secondly, the DEP then added other research guidelines and determined exactly what needed to be in the study and what did not belong. There were also budget and time constraints. The most constricting factor was the large body of existing data possessed by the DEP that was provided to the researchers and report writers. Because of the time restrictions, only a small amount of additional raw data could be added.

And most importantly, similar to the WVU Water Research Institute (WVU WRI) report from two years ago, it must be kept in mind that these types of studies, initiated by those elected to our well-lobbied legislature and funded and overseen by a state agency, do not occur in a political power vacuum. It was surely anticipated that the completed report might have the ability to affect the growing natural gas industry – which is supported by most in the political administration. Therefore, we must be cautious here. The presence and influence of political and economic factors need to be considered. Also, for universities to receive research contracts and government paid study requests, the focus must include keeping the customer satisfied.

My comments below on the report’s methods and findings are organized into three broad and overlapping categories:

  • GOOD  –  positive aspects, good suggestions, important observations
  • GENERAL  –  general comments
  • FLAW  –  problems, flaws, limitations
  • MOVING FORWARD  – my suggestions & recommendations

I. Water Quality: EPA Test Protocols & Datasets

Marcellus Shale (at the surface)

Marcellus Shale (at the surface)

GENERAL  It is obvious that a very smart and well-trained set of researchers put a lot of long, detailed thought into analyzing all of the available data. There must be tens of thousands of data points. Meticulous attention was put into how to assemble all of the existing years’ worth of leachate chemical and radiological information.

GOOD  There is an elaborate and detailed discussion of how to best analyze everything and how to utilize the best statistical methods and generate a uniform and integrated report. This was made difficult with non-uniform time intervals, some non-detect values, and some missing items. The researchers used a credible process, explaining how they applied the various appropriate statistical analysis methods to all the data. They provided some trends and observations and draw some conclusions.

FLAW 1  The most glaring flaw and the greatest limitation pertaining to the data sets is the nature of the very data set, which was provided to the researchers from the DEP. It is to the commendable credit of the DEP that the leachate at landfills receiving black shale drill cuttings from the Marcellus and other shale formations were, from the beginning, required to start bi-monthly testing of leachate samples at landfills that were burying drill waste products. And in general, when compared to on-site disposal as done for conventional wells, it was initially a good requirement to have the drill cuttings put into some type of landfill; that way we could keep track of where the drill cuttings are located when there are future problems.

To the best of my knowledge, until the states in the Marcellus region started allowing massive quantities of black shale waste material to be put into local landfills, we have never knowingly deposited large quantities of known radioactive industrial waste products into generic municipal waste landfills. The various waste products and drill cuttings of Marcellus black shales have been known for decades by geologists and radiochemists to be radioactive. We know better than to depose of hazardous radioactive waste in an improper way. Therefore, it is very understandable that we might not know how to best solve the problems of this particular waste product. This was and still is new territory.

FLAW 2  All of the years of leachate test samples were processed for radioactivity using what is called the clean drinking water test protocols, also referred to as the EPA 900 series. Three years ago, given the unfamiliarity of regulatory agencies with the uniqueness of this waste problem, we chose the wrong test protocol for assessing leachate samples. We speculated that the commonly used and familiar clean drinking water test procedure would work. So now we have a massive set of test results all derived from using the wrong test protocol for the radiologicals. Fortunately, all of the chemistry test results should still be reasonably useful and accurate.

At first, three years ago, this was understandable and possibly not an intentional error. Now it is widely known by hydrogeologists and radiochemists, however, that the plain EPA 900 series of test methods for determining the radioactivity of contaminated liquids do not work on liquids with high TDS — Total Dissolved Solids. Method 900.0 is designed for samples with low dissolved solid like finished drinking water supplies.

Despite this major and significant limitation, the effort by Marshall University still has some utility. For example, doing comparisons between and among the various landfills accepting drill waste might provide some interesting observations and correlations. It is clearly known now, however, that the protocols that were used for all samples from the start when testing for gross alpha, gross beta and radium-226 and radium-228 in leachate, can only result in very inaccurate, under-reported data. Therefore, it is not possible to draw any valid conclusions on several very important topics, including:

  • surface water quality,
  • potential ground water contamination,
  • exposure levels at landfills and public health implications,
  • and policy and regulations considerations.

Labs certified to test for radiological compounds and elements are very familiar with the 900 series of EPA test procedures. These protocols are intended to be used on clean drinking water. They are not intended to be used on “sludgy” waters or liquids contaminated with high dissolved solids like all the many liquid wastes from black shale operations like flowback and produced water and brines and leachate. The required lab process for sample size, preparation, and testing will guarantee that the results will be incorrect.

In no place in the final 195 page report have I seen any discussion of which EPA test protocol was used for the newer samples and why was it used. It has also not yet been seen in the 2,300+ pages of supportive statistical and analytical results, either. The fact that the wrong protocol was used three years ago is very understandable. However, this conventional EPA 900 series was still being used on the additional very recent (done in fall of 2014 and spring of 2015) samples that were included in the final report. The researchers, without any justification or discussion or explanations continued to use the wrong test protocol.

The clean drinking water procedures should have been used along with the 901.1M (gamma spec) process, for comparison. It is understandable for the new data to be consistent and comparable with the very large existing dataset that a case could be made for using the incorrect protocol and the proper one also. There should have been a detailed discussion of what and why any test method was being used, however. That discussion is usually one of the first topics investigated and explained in the Methods section. Having that type of discussion and justification seems to represent a basic science method and accepted research process – and that omission is a serious flaw.

MOVING FORWARD  We all know that if we want to bake an appetizing and attractive cake we must use the correct measuring cups for the ingredients. If we want to take our child’s temperature we need an accurate thermometer. When our doctor helps us understand our blood test results, we all want to be confident the right test was used at the lab. The proper test instrument, recently calibrated and designed for the specific sample, is crucial to get useable test results from which conclusions can be drawn and policy enacted.

It seems that the best suggestion so far to test high TDS liquids similar to leachate would be to use what is referred to as Gamma-ray Spectrometry with a high purity germanium instrument with at least a 21-day hold period (30 days are better), while the sample is sealed then counted for at least 16 hours. Many of the old leachate test results indicate high uncertainties that might be attributed to short hold times and short counting times. This procedure is referred to as the 901.1 M (modified). If the sample is sealed, the sample will reach about 99% equilibrium after 30 days. Radon 222 (a gas) must not be allowed to escape.

The potential environmental impacts to water quality section of this report seems to demonstrate that if you do not want to find out something, there are always justifiable options to avoid some inconvenient facts. Given the very narrow scope as defined, some the Marshall University folks did not seem to have the option to stray into important scientific foundational assumptions and, for the most part, just had to work with the stale data sets given to them. All of which, as we have known for close to a year now, have used the wrong test protocol. Therefore we have incorrect results of limited value.

II. Marcellus is Radioactive

GOOD 1  Of course, geologists have known that the Marcellus Shale is radioactive for many decades, but also for decades there has been great reluctance by the natural gas exploration and production companies to acknowledge this fact to the public. And finally we now have a public report that clearly and unambiguously states that Marcellus shale is radioactive. Interestingly enough, it was not much more than a year ago that some on the WV House of Delegates Judiciary Committee, seemed to be echoing the industry’s intentional deception by declaring that:

…it was only dirt and rock…

So this report represents progress and provides a very valuable contribution to beginning to recognize some of the potential problems with shale wastes and their disposal challenges.

GOOD 2  Another very important advance is that finally after eight years of drilling here in Wetzel County, we now have a test sample from near the horizontal bore. The WVU WRI study researchers were never given access to any samples taken from the horizontal bore material itself, however. That was, of course, what they were supposed to have been allowed to do, but they were only given access to study material from the vertical section of the well bore. This report describes how we are getting closer to actually testing good samples of the black shale. It seems that we have gotten closer – but let’s see how close.

Page 11 describes that only three Antero wells in Doddridge County were chosen as the place to try to obtain samples from the horizontal bore. Considering that over 1,000 deviated/horizontal wells or wells with laterals have been drilled in the past few years, that number represents a very small fraction of wells drilled: less than .3%. Even if a high quality sample could have been obtained it might be a challenge to extrapolate test results to the waste being produced from the other wells in WV. These limitations are completely ignored in the report, however. Given the available documentation from the DEP, this seems to be a serious flaw that compromises the reliability of the entire report.

III. Samples From Vertical vs. Horizontal Well Bores

FLAW  The actual samples tested from at least two of the three wells used in the study do not seem to be from the horizontal bore material. The sample from the third well might have come from the horizontal bore, but just barely. There is no way to know for sure. I will try to show this within the below chart using information provided by Antero to DEP Office of Oil & Gas. This information is in state records on Antero’s well plats, which become part of the well work application and also part of the final permit.

Table 1. Details about the samples taken from three Antero wells in Doddridge County, WV – and my concerns about the sampling process*

Antero well ID API # Sample’s drilling depth Marcellus depth** Horizontal bore length** Comments / Issues
Morton 1H 47-017-06559 6,856 ft. 7,900 TVD*** 10,600 ft. ~1,044 ft. short of reaching Marcellus formation
McGee 2H 47-017-06622 6,506 ft. 6,900 TVD 8,652 ft. ~394 ft. short of reaching Marcellus
Wentz1 H 47-017-06476 8,119 ft. 7,900 TVD 8,300 ft. Just drilled into Marcellus by 219 ft.
* Original chart found on page 11 of report
** Based on information from Antero’s well plat
*** TVD = Total Vertical Depth

Antero is an active driller in Doddridge County. If any company knows where to find the Marcellus formation it is that company. Well plats are very detailed, technical documents provided to the DEP by the operator regarding the well location, watershed, and leased acres and property boundaries. We need to trust that the information on those plats is accurate and has been reviewed and approved by the permitting agency. Those plats also give the depth of the Marcellus and the length and heading of the lateral or horizontal bore. The Marshall University report gives the drilling depth when the sample was taken on the surface. Using these available well plat records from the DEP it appears that at two of the wells the sample (and its test results included in the report) came from material produced when the experienced drilling operator was not yet into the shale formation.

On the third well, Wentz 1H, the numbers seem to indicate that the sample was taken when the driller said that they were just barely within the shale layer – by 219 feet. Since the drill cuttings take some time to return to the surface from over 7,000 feet down, drilling just a few hundred feet would not at all guarantee that the returned cuttings were totally from the black shale. The processing of the drill cuttings at the shaker table and separator and centrifuge and the mixing in the tubs all cast some doubt on whether the sample, wherever it was taken from, was truly from the horizontal bore material.

On page 11 there is a clear and unambiguous statement:

Three representative sets of drill cuttings from the horizontal drilling activities within the Marcellus Shale formation were collected.

A successful attempt to get three such samples might have then allowed an appropriate waste characterization to be done as needed to accomplish the five required research topics listed in the report’s cover letter. Only an accurate chemical and radiological waste characterization would have allowed scientifically justifiable conclusions to be formulated and then allow for accurate legislation and regulations. It does not seem that West Virginia yet has the required scientific data upon which to confidently formulate laws and regulations to protect public health with regard to shale waste disposal.

Would it not seem prudent – if one wanted a good, representative sample – to make absolutely sure that the operator was, in fact, drilling in the black shale and that the cuttings returning to the surface were, in fact, from the Marcellus bore? That approach would have been eminently defensible and easily accomplished by just waiting for drilling to progress into the lateral bore far enough that the drill cuttings returning to the surface were in fact from the black shale. There might be plausible explanations for this apparent inconsistency or error. Of course, it might be speculated that the Antero-provided information on the well plats is incorrect and not intended to be accurate, or perhaps the driller is not really sure yet where the Marcellus layer starts. There may be many other possible scenarios of explanations. Time will tell.

IV. Research Observations Review

Landfill disposal of drill cuttings

Landfill disposal of drill cuttings

GOOD There are a number of recommendations and suggestions in the study on landfills and leachate related conditions. It seems that a number of these proposals are very accurate and should be implemented. For example:

The report clearly restates that drill cuttings are known to contain radioactive compounds. Since all landfill liners will eventually leak, and since landfills already have ground water test wells for monitoring for potential ground water contamination due to leaking liners, then the well samples should be tested for radiological isotopes. Good idea. They are not required to do that now, but this recommendation should be implemented immediately (pgs. 17 and 21).

GOOD The report recommends that the Publicly Owned Treatment Works (POTW) or in the case of Wetzel County, the on-site wastewater treatment plants, should also test their effluent for radioactive isotopes. This is very important since there is no way to efficiently filter out many of the radioactive isotopes. Such contaminants will pass through traditional wastewater treatment plants.

It is also very useful that the report recommends that all the National Pollution Discharge Elimination System (NPDES) limits at the POTWs be reviewed and required to take into consideration the significantly more challenging chemical and radiological makeup of the shale waste products.

V. Economic Considerations on an Industry Supported Mono-Fill

The legislature asked that the DEP evaluate the feasibility of the natural gas industry to build, own, or operate its own landfill solely for the disposal of the known radioactive waste. This request seems to be a very reasonable approach, since for decades we have only put known radioactive waste products into dedicated landfills that are exclusively and specifically designed for the long term storage of the special waste material.

The discussion of the economic considerations is extremely complete and detailed. They are given in Appendix I and take into consideration a very thorough economic feasibility study of such a proposed endeavor. This section seems to have been compiled by a very talented professional team.

FLAW  However, some of the basic assumptions are a bit askew. For example:

The initial Abstract of the financial analysis states that two new landfills would be needed because we do not want to have the well operators to drive any further than they do now. Interesting. This seems to be not too different than a homeowner while in search for privacy and quiet, builds a home far out into the country and then expects the public sewage lines to be extended miles to his new home so he would not have to incur the cost of a septic system. Homebuilders in rural settings should know they will have to incur expenses for their waste disposal needs. Should gas companies expect that communities to provide cheap waste disposal for them?

More than 15 pages later, the most important aspect is clearly stated that, “…the most salient benefit of establishing a separate landfill sited specifically to receive (radioactive) drill cuttings would be the preservation of existing disposal capacity of existing fills for future waste disposal”. Meaning for my (our) grandchildren. See page 175.

Comprehensive and sound financial details later explain that having the natural gas operators build, operate, and eventually close their own radioactive waste depository landfill would involve a lot of their capital and involve some risk to them. It is stated that their money would be better used drilling more wells. The conclusion then seems to be that, all around, it is simply cheaper and less risky for the gas industry to put all their waste products into our Municipal Waste Landfills, and later residents should incur the costs and risk to build another land fill for their household garbage when needed.

VI. Report Omissions

  1. Within the report section dealing with the leachate test results, it is casually mentioned that not only do the landfills receiving shale waste materials have radioactive contaminated leachate, but the other tested landfills do, as well. However, rather than raising a very red flag and expressing concern over a problem that no one has looked into, the report implies we should not worry about any radioactive waste because it might be in all landfills (pg. 139).
  2. Nowhere within the radiological discussion is there any mention of what might be called speciation of radioactive isotopes. The report does state that the test for both gross alpha and gross beta, are considered a “scanning procedure.” The speciation process is sort of a slice and dice procedure, showing exactly what isotopes are responsible for the activity that is being indicated. This process, however, does not seem to have been done on the landfill leachate test samples. The general scanning process cannot do that. Appendix H, pages 141-142, contains detailed facts on radiation dose, risk, and exposure. This might have been a good place to also discuss the proper EPA testing protocols, used or not used, and why.
  3. A short discussion of the DEP-required landfill entrance radiation monitors is included on page 146. The installed monitors are the goalpost type. Trucks drive between them at the entrance and when they cross the scales. It seems that the report should have emphasized that that type of monitor will primarily only detect high-energy gamma radiation. However what is omitted on page 144 is that the primary form of decay for radium-226 is releasing alpha particles. The report is ambiguous in saying the decay products of radium-226 include both alpha particles and some gamma radiation, but radium-266 is not a strong gamma emitter. It is very unlikely that a normal steel enclosed roll-off box would ever trip the alarm setting with a load of drill cuttings. However those monitors are still useful since they will detect the high-energy gamma radiation from a truck carrying a lot of medical waste (pg. 17).
  4. It is stated on page 144 that the greatest health risk due to the presence of radium-226 is the fact that its daughter product is radon-222. Radium-226 has a half-life of 1,600 years, compared to radon’s 3.8 days. This difference might seem to imply that radon is less of a concern. Given the multitude of radium-226 going into our landfills means that we will be producing radon for a very long time.

VII. Resource Referenced in Article

Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

Landfill disposal of drill cuttings

Has radioactivity risk from oil and gas activity been underrated?

Reviewing a Pennsylvania TENORM Study

By Juliana Henao, Communications Intern

Technologically-enhanced, naturally-occurring radioactive materials, also known as TENORM, are produced when radionuclides deep in the earth are brought to the surface by human activity such as oil and gas drilling. The radioactive materials, which include uranium (U), thorium (th), potassium-40 (K-40) and their decay products, occur naturally in the environment. These materials are known to dissolve in produced water, or brine, from the hydraulic fracturing process (e.g. fracking), can be found in drilling muds, and can accumulate in drilling equipment over time.

According to the EPA, ~30% of domestic oil and gas wells produce TENORM. Surveys have shown that 90% of the wells show some TENORM concentrations, while others have nothing at all. However, with increasing natural gas exploration and production in Pennsylvania’s Marcellus Shale, there is a parallel increase in TENORM. According to Dr. Marvin Resnikoff, an international expert on radiation, drilling companies and geologists locate the Marcellus Shale layer by way of its higher level of radiation.

Bringing more of this TENORM to the surface has the potential to greatly impact public health and the environment. Since 2013, the Pennsylvania Department of Environmental Protection (PA DEP) has been gathering raw data on TENORM associated with oil and gas activity in the state. The study was initiated due to the volume of waste containing high TENORM concentrations in the state’s landfills, something that is largely unregulated at the state and federal level.  In January 2015, the PA DEP released a report that outlined their findings and conclusions, including potential exposures, TENORM disposal practices, and possible environmental impacts.

Radioactivity Study Overview

Drilling mud being collected on the well pad

This review touches on the samples tested, the findings, and the conclusions drawn after analysis. The main areas of concern included potential exposure to workers, members of the public, and the environment.

The samples gathered by the DEP came from 38 well sites, conventional and unconventional, by testing solids, liquids, ambient air, soils, and natural gas near oil and gas activity in Pennsylvania. All samples contained TENORM or were in some way impacted by TENORM due to oil and gas operations. The samples were mainly tested for radioactive isotopes, specifically radium, through radiological surveys.

The PA DEP concluded in the cases of well sites, wastewater treatment plants (POTW), centralized wastewater treatment plants, zero liquid discharge plants, landfills, natural gas in underground storage, natural gas fired power plants, compressor stations, natural gas processing plants, radon dosimetry (the calculation and assessment of the radiation dose received by the human body), and oil and gas brine-treated roads that there is little potential for internal radiation exposure to workers and members of the public. In spite of this, each section of the report typically concluded with: however, there is a potential for radiological environmental impacts…

Examples of these findings include:

  • There is little potential for radiological exposure to workers and members of the public from handling and temporary storage of produced water on natural gas well sites. However, there is a potential for radiological environmental impacts from spills of produced water from unconventional natural gas well sites and from spills that could occur from the transportation of this fluid.
  • There is little potential for radiological exposure to workers and members of the public from sediment-impacted soil at landfills that accepted O&G waste for disposal.  However, there may be a radiological environmental impact to soil from the sediments from landfill leachate treatment facilities that treat leachate from landfills that accept O&G waste for disposal.
  • Radium 226 was detected within the hydraulic fracturing fluid ranging from 64.0-21,000 pCi/L. Radium-228 was also detected ranging from 4.5-1,640 pCi/L. The hydraulic fracturing fluid was made up of a combination of fresh water, produced water, and reuse flowback fluid. There is little potential impact for radiological exposure to workers and members of the public from handling and temporary storage of flowback fluid on natural gas well sites. However, there is a potential for radiological environmental impacts from spills of flowback fluid on natural gas well sites and from spills that could occur from the transport of this fluid.
  • Nine influent and seven effluent leachate samples were collected at the nine selected landfills.  Radium was detected in all of the leachate samples. Radium-226 concentrations were detected in produced water samples ranging from 40.5 – 26,600 pCi/L. Radium-228 concentrations were also detected ranging from 26.0 – 1,900 pCi/L. The Ra-226 activity in unconventional well site produced water is approximately 20 times greater than that observed in conventional well site produced water. The ratio of Ra-226 to Ra-228 in unconventional well site produced water is approximately eight times greater than that found in conventional well site produced water.  (Sections 3.3.4 and 3.6.3) (PA DEP TENORM study report section 9.0)

According to Melody Fleck from Moshannon Group- Sierra Club Executive Committee:

While the report comprehensively covers the processes from drilling to end users, the number of samples collected and analyzed are very sparse for a state-wide study. Just to give an idea, only 8 well sites were sampled during the flowback phase and of the 8 only 4 had enough volume to analyze. Of 14 drill mud samples collected, only 5 were analyzed as liquids, and alpha & beta analysis was only done on one sample.

Obtaining the proper sample size is often a major barrier for field studies. Additional research needs to be conducted with a larger sample size and more rigorous exposure monitoring to determine specific risk metrics for workers and the public.

Current Handling of TENORM

From drilling to distribution, there are many topics of concern associated with TENORM; however, we will focus on the current treatment of TENORM waste, the release of data, and the transparency of this issue.

On a federal level, there are no specific regulations governing many aspects of TENORM, such as sludge or solids containing TENORM from water treatment plants. Additionally, if concentrations of U or Th make up less than .05% by weight, they are seen as an “unimportant quantity” and are exempt from NRE regulation. Currently, 13 states regulate TENORM with varying degrees of standards. Hazardous waste facilities in each state can choose to accept TENORM materials as long as they don’t exceed certain concentrations.

Today, about 12 of PA’s 50 landfills accept such radioactive waste from oil and gas activity at a 1:50 dilution ratio (related to their other intake sources). Under RCRA’s Land Disposal Restrictions, “dilution is prohibited as treatment for both listed and characterized wastes.”

According to the DEP report, hydraulic fracturing produces an enormous stream of waste by-products. Safe disposal of this waste has not yet been devised. A few of the conclusions concerning TENORM disposal and treatment in the report listed some areas of concern, identified below:

  1. Filter cake [1] and its radiological environmental impact if spilled, and
  2. The amount of radioactive waste entering the landfills in PA, which reached 430,317 tons in the first 10 months of 2014.

In unison with the conclusions were recommendations, where the report “recommends considering limiting radioactive effluent discharge from landfills, and adding radium-226 and radium-228 to annual sample analysis of leachate from landfills.” Additionally, the report states that if something such as filter cake spills, it will bring into question the safety of long-term disposal and suggest a protocol revision.

Public Health Concerns

The report identified two places where there is a higher than average radioactive exposure risk for workers and community members of the public: specifically at centralized wastewater treatment plants and zero liquid discharge plants that treat oil and gas wastewater. An additional unknown is whether there is a potential inhalation or ingestion hazard from fixed alpha and beta surface radioactivity if materials are disturbed. As a general precaution, they recommend the evaluation of worker’s use of protective equipment under certain circumstances.

Although research has not come to a consensus regarding a safe level of radiation exposure, it should not be assumed that any exposure is safe. Past research has evaluated two types of radiation exposure: stochastic and non-stochastic, both of which have their own risks and are known to be harmful to the human body. The EPA has defined stochastic effects as those associated with long-term, low level exposure to radiation, while non-stochastic effects are associated with short-term, high-level exposure. From past scientific research, radiation is known to cause cancer and alter DNA, causing genetic mutations that can occur from both stochastic and non-stochastic exposure. Radiation sickness is also common, which involves nausea, weakness, damage to the central nervous system, and diminished organ function. Exposure levels set by the EPA and other regulatory agencies fall at 100 millirem (mrem) per year to avoid acute health effects. As a point of reference, medical X-rays deliver less than 10 mrem, and yearly background exposure can be about 300 mrem.

In the report, Radiological Dose and Risk Assessment of Landfill Disposal of TENORM in North Dakota, Argonne National Laboratory researchers suggest that the exposure to workers be limited and monitored. In many of their studies, they found the doses exceed the 100 mrem/year level in the workers when the appropriate attire is not worn during working hours, which raised some concern.

The DEP deems certain radiation levels “allowable”, but it should be noted that allowable doses are set by federal agencies and may be arbitrary. Based on the PA DEP’s report, consumers of produced gas can get up to 17.8% of their yearly radiation allowance, while POTW workers could get up to 36.3% of their yearly allowable dose. According to the Nuclear Information and Resource Service, radiation bio-accumulates in ecosystems and in the body, which introduces a serious confounder in understanding the risk posed by a dose of 17.8% per year.

Transparency of Radiation Risk

The DEP has been gathering data for their TENORM report since 2012. In July of 2014, Delaware Riverkeeper Network filed a Right-to Know request to obtain the information that the DEP had collected in order for their expert to analyze the raw data. The department refused to release the information, insisting that “the release of preliminary invalidated data, including sample locations, could likely result in a substantial and demonstrable risk of physical harm, pose a security risk and lead to erroneous and/or misleading characterizations of the levels and effects of the radioactive risks.” Essentially, the DEP was equating the risks of radioactive material to the risks of releasing raw data — two incomparable risks. DRN appealed, claiming that they simply sought the raw information, which is presumed public unless exempt, and would have no risk on the public. PA DEP was ordered to release their records to DRN within 30 days.

Conclusion

One observation that you could take from this report is the lack of regulatory advancement. The study is filled with suggestions, like:

  • Radium should be added to the PA spill protocol to ensure cleanups are adequately characterized,
  • A limited potential was found for recreationists on roads with oil and gas brine from conventional natural gas wells–further study should be conducted, and
  • More testing is needed to identify areas of contamination and any area should be cleaned up.

Intent doesn’t make the changes; action does. Will any regulations change, at least in Pennsylvania where radioactive materials are returning to the surface on a daily basis? There seems to be no urgency when it comes to regulating TENORM and its many issues at the state level. Are workers, citizens, and the environment truly being protected or will we wait for a disaster to spur action?

Footnotes:

[1] This is the residue deposited on a permeable medium when a slurry, such as a drilling fluid, is forced against the medium under pressure. Filtrate is the liquid that passes through the medium, leaving the cake on the medium.

Utica Shale Drill Cuttings Production – Back of the Envelope Recipe

By Ted Auch, OH Program Coordinator, FracTracker Alliance

Ohio is the only shale gas state in the Marcellus and/or Utica Shale Basin that has decided to go “all in.” i.e. The state is moving forward with shale gas production, Class II Injection Well disposal of brine waste from fracking, and more recently the processing and disposal of drill cuttings/muds via the state’s Solid Waste Disposal (SWD) districts and waste landfills. The latter would fall under the joint ODNR, ODH, and EPA’s September 18, 2012  Solidification and Disposal Activities Associated with Drilling-Related Wastes advisory. It occurred to us that it might be time to try to estimate how much of these materials are produced here in Ohio on a per-well basis using basic math, data gleaned from Ohio’s current inventory of Utica wells and the current inventory of PLAT maps, and some broad assumptions as to the density of Ohio’s geology.

Developing the Estimate

1) Start with a 341 Actual Utica well lateral dataset generated utilizing the ODNR Ohio Oil & Gas Well Database PLAT inventory or the current inventory of 1,137 permitted Utica wells. Generate a Straight Line lateral dataset by converting this data from “XY To Line” with the following summary statistics:

Variable

Actual

Straight Line

#

341

1,137

Minimum

186

50

Maximum

20,295

12,109

Sum

2,196,856

7,190,889

Mean

6,442 ±1,480

6,386 ±1,489

Median

6,428

6,096

2) Average Vertical Depth for 109 Utica wells utilizing data from the ODNR RBDMS Microsoft Access database = 6,819 feet (207,843 centimeters)

Average Lateral + Vertical Footage = 13,205-13,261 total feet (402,488-404,195 centimeters) (Figure 1)

Ohio Utica Shale Actual Vs Straight Line Lateral Lengths

Fig. 1. An example of Actual and Straight Line Utica well laterals in Southeast Carroll County, Ohio

3) We assume a rough diameter of 8″ down to 5″ (20-13 centimeters) for all of 1) and 14″ to 8″ (36-20 centimeters) for the entirety of 2)

4) The density of 1) is roughly 2.61 g cm3 assuming the average of seven regional shale formations (Manger, 1963)

5) None of the materials being drilled through are igneous or metamorphic (limestone, siltstone, sandstone, and coal) thus the density of 2) is all going to be
≈2.75 g cm3

6) The volume of the above is calculated assuming the volume of a cylinder
(i.e., V = hπr2):

    1. Σ of Actual Lateral Length 49,205,721 cm3 * 2.61 g = 128,180,904 g
    2. Σ of Actual Lateral Length 153,991,464 cm3 * 2.75 g = 423,476,526 g

Average Lateral + Vertical Volume = 551,657,430 grams = 1,216,195 pounds =
608 tons of drill cuttings per Utica well * 829 drilled, drilling, or producing wells = 504,113 million tons

To put these numbers into perspective, the average Ohio household of 2.46 people generates about 3,933 pounds of waste per year or 1.78 metric tons.

7) Caveats include:

    • The coarse assumptions as to density of materials and the fact that these materials experience significant increases in surface area once they have been drilled through.
    • The assumptions as to pipe diameter could be over or underestimating drill cuttings due to the fact that we know laterals taper as they near their endpoint. We assume 45% of the vertical depth is comprised of 14″ diameter pipe, 40% 11″ diameter pipe, and 15% 8″ pipe. Similarly we assume the same percentage distribution for 8″, 6.5″, and 5″ lateral pipe.

Ohio Drilling Mud Generation and Processing

Caroll-Columbiana-Harrison Ohio Solid Waste District Drilling Muds Processed (January, 2011-April, 2014)

Fig. 2. Month-to-month and cumulative drilling muds processed by CCHSWD, one of six OH SWDs charged with processing shale gas drilling waste from OH, WV, and PA.

Ohio’s primary SWDs responsible for handling the above waste streams – from in state as well as from Pennsylvania and West Virginia – are the six southeastern SWDs along with the counties of Portage and Mahoning according to several anonymous sources. However, when attempting to acquire numbers that speak to the flows/stocks of fracking related SWD waste (i.e., drilling muds) the only district that keeps track of this data is the Carroll-Columbiana-Harrison Solid Waste District (CCHSWD). The CCHSWD’s Director of Administration was generous enough to provide us with this data. According to a month-over-month analysis they have processed 636,450 tons generating a fixed fee of $3.5 per ton or $2.23 million to date (Figure 2). This trend translates into a 1,046-1,571 ton monthly increase depending on how you fit your trend line to the data (i.e., linear Vs power functions) or put another way annual drilling mud increases of 12,546-18,847 tons.