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History + Science + Common Sense = ???

Prepared by:

W.E. Kennedy, Jr.

Public Health • Basic interactions of people and their

environment • Must understand, assess, and control Impacts of people on their environment Impacts of the environment on people

• Mineral industry materials may contain radioactive materials (NORM/TENORM) What are these materials? When is this a concern? When/how is it regulated?

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Introduction • Sources of NORM/TENORM span many

human activities Known as a potential source of radiation

exposure for about 100 years Mineral industry materials may contain

radioactive materials • How should we best protect individuals and

the environment? • We are at the confluence of history, science,

and common sense.

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Acknowledgements • NCRP/HPS Midyear TENORM in

Unconventional Oil & Gas Production Workshop, February 1-2, 2016 Masoud Beitollahi Dr. John R. Frazier Jared W. Thompson Daniel f. Shank Mauricio Escobar David Allard Janet Hohnson Arthur S. Rood Alan McArthur Joseph J. Weismann Andrew J. Lobardo Mel B. Hebert

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Outline • Definitions • History Sources and types of NORM/TENORM

• Science What we know; what we need to know

• Common Sense Radiation dose in perspective

• ??? Regulations; the future?

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Definitions • NORM: Naturally Occurring Radioactive

Material – natural radionuclides in the environment (uranium, thorium, radium, radon…) Some oil and gas drilling waste (shale) Fertilizer (from phosphate ores – uranium) Rare earth mine tailings (uranium, thorium) Ceramic products (uranium in clay) Welding rods (thorium sands in coatings)

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Definitions (Cont’d) • TENORM: Technologically Enhanced

NORM – natural material whose radioactive concentrations have been enhanced by human activities including: Oil & gas pipe scale Oil & gas sludge Selected mining wastes Coal ash (concentrated uranium & thorium)

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Example Half-lives • Uranium-238 (in soil) 4.5 billion years

• Radium-226 (in soil - produces radon) 1,600 years

• Radon-222 (in soil and air) 3.8 days

• Polonium-214 (radon progeny) 164 microseconds (0.000164 s)

Example: Coal Ash • Uranium concentrates in coal ash during

combustion by about 10 times • Fly ash used in concrete products can

increase background in homes • In 2009, 850 million tons of coal burned in US 1,100 tons of Uranium; 2,700 tons of Thorium At 1 ppm in coal, enough Uranium if used is a fast

reactor to exceed the energy equivalent in coal Ash mined for uranium in the 1970s

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Summary of TENORM Sources EPA Data 2003

Material or Waste

Radium Concentration (Bq/g) Low Average High

U.S. Soil 0.007 N/A 0.16 Petroleum Scale <0.009 <7 >3,900 Geothermal Scale 0.37 4.9 9.4 Water Treatment Filters

N/A 1,600 N/A

Coal Bottom Ash 0.06 0.13-0.17 0.28 Coal Fly Ash 0.07 0.23 0.36 Phosphate Ore 0.26 0.64-1.5 0.23-2.0 Titanium Ore Waste 0.14 0.44 1.7

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Oil Field Waste: Example Radionuclide Content

Note: Typical radium-226 in soil is ~0.037-0.37 Bq/g (EPA Data)

Radionuclide

Average Sludge (Bq/g)

Average Scale (Bq/g)

210Po 2 13

210Pb 2 13

226Ra 2 13

228Th 0.7 4

228Ra 0.7 4

Total: 8 49

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History • Uranium/radium in geologic formations

known and measured since ~1920 Supporting the expanding radium industry

• Early 1970s recognition of TENORM in natural gas and LPG processing sites Potential for above background doses Specific actions by industry recommended

• Early 1980s recognition of TENORM in oil fields CRCPD, API, industry assessed sources

and potential doses

Conventional Oil & Gas Industry • NORM/TENORM present in all phases • Concentrations depend on geology Higher concentrations in production phase

(scale/sludge) Drill cuttings Produced water/flowback water Radon decay products in gas production equipment

• Gas well drillers often use well logging to determine radiation levels to find gas

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Conventional Oil Field Waste • Historically we know NORM radionuclides

may be concentrated in the oil recovery Radium is more soluble in brine solutions than

uranium or thorium Carbonates and sulfates of calcium, barium, and

strontium may precipitate as pipe scale (changes in temperature and pressure)

Radium will also precipitate in pipe scale Sludge in refineries may also contain radium Pipe recycling and solid waste issues result Legacy sites!

Pipe Scale q

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Pipe Scale q

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Oil Field Wastes Production Water Production Sludge

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Gas Pipeline “Pigging” Waste

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• Measurable radon in natural gas Results in Pb-210;

22 year half-life Po-210 5.3 MeV alpha Po is electrostatic Po attaches to rust Potential inhalation

hazard

TENORM in Pipeline Pigs

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• Unconventional rock stimulation Injection of fluids (water), sand, and/or

chemicals below ground to the host rock under high pressure

• Pressure fractures host rock to induce cracks – horizontal drilling a key! Sand/chemicals open cracks allowing

oil, gas, and brine water to flow more freely

What is Fracking?

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• 1857 – Preston Barmore, Gunpowder Intended to increase production

• 1865 – Col. Edward Roberts “Superincumbent fluid-tamping” (damped

explosions to amplify effects) • Legacy lives on with the Tallini and Otto

Cupler torpedo Company Still “shooting” wells today!

A Brief History of Fracking

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• 1930s – innovations using non-explosive liquids to increase production

• 1947 – Floyd Farris of Stanolind O&G Studied the relationship between output and

the quantity of pressurized treatment • 1947 – Grant County, Kansas experiment Birth of modern day fracking

• Quickly commercialized in the 1960s Kansas/Oklahoma/Texas

A Brief History of Fracking

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• My experience in Kansas in the 1960s • 1975 – President Ford promoted

development of shale oil resources as part of his overall energy plan (reduce imports)

• 1990s – Modern day fracking George P. Mitchell, combined fracking with

horizontal drilling; greatly increased production

A Brief History of Fracking

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+ Science • Horizontal drilling is the key! Technology opens up a larger well

“footprint” Relies on expensive equipment/

technology As production declines over time, a site

may be “re-fracked” • New technologies – 3D Seismic

mapping – computer controls

• Typically involves five steps: Develop well pad, drill to formation

(> 1,000 m), horizontal drilling (may involve numerous directions) Hydraulic fracturing Capture/process gas Storage, treatment, disposal of

water/wastes Decommissioning the well pad

Shale Gas Fracking

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Fracking Schematic

From USGS

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• Follow the money 2000s; global production limited Rising prices Balance increased fracking costs after

~2005 • If not for higher prices, there would be

no U.S. oil & gas surge • Current low oil prices have reduced

domestic exploration and production

Current U.S. O&G Surge

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From USGS

Fracking Equipment

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From USGS

Drill Rig

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U.S. Shale Play Locations

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• Water issues Large quantities (15,000 m3) used as part of

fracturing fluids; depletion of water resources Waste water; flow back water (injection

fluids), production water (saline water liberated along with O&G)

• API estimates: 10 barrels of water recovered per barrel of oil; 18 billion barrels of waste fluid produced per year

Environmental Issues

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From USGS

Fracking Waste Water

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• Radiation exposures during operations Emissions (air/water) Radon Contamination control Lack of regulated disposal

• Public Radon, transportation, waste management

• Legacy contamination after well site decommissioning

Special Concerns

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• TENORM fracking waste significant Unconventional natural gas recovery 2001, required monitoring of solid waste

and development of an “Action Plan” • Identified potential issues: Potential worker exposures Possible public exposures Environmental contamination (?) Waste disposal

PA Study Background

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• 2012, scope, sampling plan, QAP • Work began in 2013 and ended in 2014 Sample analysis, data analysis, and report

preparation through fall 2014 Internal DEP final review through early

winter 2014 Peer review/final study posted January

2015 Rev. 1 posted 2015

PA Study Background

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• Most comprehensive study to date Well sites and pads have low worker

exposure potential All water high in radium Potential environmental impacts (spills) ~25% of TENORM sludge over DOT Class 7

limits (packaging/shipping restrictions) Long-term monitoring of Ra in landfill

leachate needed

PA Study Conclusions

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PA TENORM Study Average Results (Bq/g or *Bq/L)

Well Sites/Pads 226Ra 238U 228Ra

Vertical Cuttings 0.1 0.06 N/A

Horizontal Cuttings 0.2 0.3 N/A

Fracking Fluid *200 N/A *20

Flowback Water *300 N/A N/A

Produced Water *200 N/A N/A

Drill Muds *80 N/A N/A

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Not Just a U.S. Problem • U.K. 1981 - present Inspection problem Onshore waste

disposal • Norway 1985 gas

TENORM Pb, Bi, Po-210 Underground

disposal

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Not Just a U.S. Problem • Holland 1985 Pb in gas

production TENORM waste in

canisters awaiting disposal

• Egypt 1985 TENORM blocked

water lines and pipelines Onshore concrete

vault disposal

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Not Just a U.S. Problem • Libya 1986 Unlined produced

water lakes TENORM waste

disposal unresolved

• Venezuela 2003 TENORM in gas

pipelines Oil pipeline sludge

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International Summary • Initial panic after “discovery” of

radioactive materials • Out reach to international community IAEA consultations Hire a health physicist Radiation surveys/sampling to quantify the

problem Development of an optimized program

based on magnitude of the problem • Revised national policies/regulations

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+ Common Sense • Kennedy’s theorem: You don’t see

what you don’t look for… • John Frazier: Reported concentrations

of Ra from oil & gas are frequently biased high Survey tendency is to scan for a “hot spot”

and report the reading • Knowledge of the presence of TENORM

is not the same as knowledge that there may be significant doses

Oil Field NORM/TENORM – Who is Exposed, and How?

• Site workers (members of the public) Radon gas Direct radiation (radium) Inhalation/ingestion of scale dust

• Maintenance workers who dismantle equipment (scale/sludge)

• Pipe/equipment recyclers

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+ Common Sense • Radon potentially of most concern in

natural gas recovery/waste disposal Household doses are quite low We know how to remediate radon disposal

from uranium mill tailings experience Radon emanation rate from pipe scale is

~10 times lower than uranium mill tailings • Performance assessment tools for LLW

are useful in evaluating landfill disposal RESRAD code can be used to conduct risk

assessments for landfills

• Recommendations: to contribute to an appropriate level of protection … against the detrimental effects of radiation exposure without unduly limiting the desirable human actions that may be associated with such exposure.

• Fundamental Principles: Justification, Optimization (regardless of source), Dose Limitation

ICRP Considerations

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• Principles: Exclusion – not amenable to control Exemption – controls are unwarranted (effort

to control is excessive compared to risk) • Types of exposures: planned, emergency,

and existing (including NORM) • Dosimetric (not WL) approach to radon • Judgement by regulatory authority on the

controllability of source

ICRP Considerations

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• A graded approach to applying regulatory controls – important decisions?

• Optimization? A balance of imposing regulatory control so that resources are not deflected away from more urgent health & safety needs

• Reference levels for existing exposures (from 1-20 mSv/yr – feasibility of control?)

• ICRP Committee 4 Task Group (TG-76)

ICRP Recommendations

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• NORM (mining/mineral + O&G) symposia Amsterdam 1997 Krefeld, Germany 1998 Brussels 2001 Poland 2004 Seville Spain 2007 Marrakesh, Morocco 2011 Beijing, China 2013 Rio De Janeiro, Brazil 2016

IAEA Activities

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• Categorization of exposures – normal? Identify ranges of activity concentrations Identification of who is exposed Identification of pathways

• Use of reference levels (concentration & dose) whenever possible

• Are changes needed to the ICRP system to accommodate NORM? ICRP TG-76

IAEA Considerations

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• New regulations for the control of exposure from NORM across EU member states Definition of scope of regulation remain

controversial Global issue because of international

mining and ore processing • A uniform and harmonized regulatory

scheme is still a hope for the future (USA)

IAEA Status

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• 1 Bq/g regulatory criterion for NORM Principle; reflects normal range of

environmental levels (1-10 Bq/g) Regulation below 1 Bq/g is not “sensible” Exception might be building materials (long

term household exposures) If >1 Bq/g; NORM to be regulated as a

“practice,” as planned exposures subject to justification, optimization, & regulation

IAEA Recommendations

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• IAEA dose assessment: Member of the public (child) living 20 m from a

2Mt deposit at 1 Bq/g of each decay chain member; annual dose not likely >0.2 mSv Supports IAEA recommendation that 1 mSv/y

is appropriate for exemption from regulation Supports current 1 Bq/g guidance

• But is exemption the optimum regulatory option for all NORM?

IAEA Conclusions

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Who Regulates NORM in the U.S.?

• EPA – sets federal radiation standards for the public

• OSHA – has authority over hazardous materials in the workplace

• States Clean Air Act Clean Water Act Workplace dose rates Waste management

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National Standards • ANSI-HPS Standards for surface and volume

radioactive materials N13.53: Control and Release of Technologically

Enhanced NORM (TRNORM) – 2009 Natural Uranium/Thorium: 30 pCi/g Radium: 3 pCi/g

N13.13: Surface and Volume Standards for Clearance Same values as N13.53

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Comparison of State Limits

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State Ra-226 (Bq/g) Comments

Oklahoma 0 No “measurable” rad

Ohio 0.18 Per state licensing exemption

Nevada 0.18 Per state licensing exemption

Texas 1.11 Per state licensing exemption

Montana 0.55-1.85 Based on MDEQ Updates

North Dakota 1.85 “Special waste” landfills

Michigan 1.85 Disposal with MDEQ approval

Penn. 10 Dose rate and volume limits

Colorado Variable 0.11-15, per facility type

Idaho 55 At RCRA Subtitle C landfills

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U.S. Future? • Given the global recognition of the

problem, what are the future/current options in the U.S.

• Confluence of history, science, and common sense State/CRCPD activities Industry evaluations and self-

regulation? A harmonized approach?

• Purpose: To prepare a Commentary that provides: Recommendations for a Uniform Approach for Hydraulic Fracturing NORM/ TENORM Waste Disposal and lays the ground work for a more comprehensive Report…

• Consistent with NCRP Mission: to formulate and widely disseminate radiation protection recommendations

NCRP SC 5-2

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David Allard PDEP Martin Barrie ORAU Phil Egidi U.S. EPA Gary Forsee Illinois Environmental Compliance Raymond Johnson Radiation Safety Counseling Inst. Andrew Lombardo PermaFix Ruth McBurney CRCPD John Frazier Consultant Co-Chair W.E. Kennedy, Jr. Dade Moeller Co-Chair

SC 5-2 Membership

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What’s Next? • Awareness training Ethical and legal responsibility to protect workers OSHA and employee right-to-know regulations

• Radiation surveys/sampling To confirm compliance and safety (PA lead)

• Workplace/environmental monitoring? • Changing regulatory/public opinion landscape Litigation avoidance!

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Industry Day • HPS Annual Meeting – Tuesday July 19 Purpose: to provide a forum for non-HP

individuals and organizations wanting to know more about potential radiation issues in industries with NORM/TENORM Goal: to promote the exchange of

information among involved stakeholders • Oral papers/posters with NORM/TENORM

theme – interactions with vendors/HPs • Other special activities and events

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Questions? Contact Information: W.E. Kennedy, Jr. (509) 942-3703 kennedy@moellerinc.com

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