North Dakota Oilfield Waste and TENORM Issues

Transcription

1 North Dakota Oilfield Waste and TENORM Issues Presentation to the Association of State and Territorial Solid Waste Management Officials - ASTSWMO August 12, 2015 Steve Tillotson, Ass t Director, Manager, Solid Waste Program Div. Of Waste Management North Dakota Department of Health stillots@nd.gov

2 ONLINE RESOURCES FROM THE DEPARTMENT Draft TENORM Rule Changes Argonne National Laboratory TENORM Study TENORM Information and Fact Sheets Argonne National Laboratory TENORM Study TENORM and Radioactive Waste Disposal Limits in Other States Guideline 42 Oilfield Exploration and Production Associated Waste Activities dexplorationandproductionassociatedwasteactivities.pdf

3 WASTE MANAGEMENT ISSUES DURING THE BAKKEN OIL BOOM Municipal Solid Waste; Oilfield Exploration and Production (Special) Waste; Spills, Releases, Pipeline Breaks; TENORM (Technicologically Enhances Naturally Occurring Radioactive Materials); ARGONNE Labs Study and Proposed Rules

4 Large Influx of Waste to Western ND MSW Landfills Facility Name % Incr Minot Landfill 42,714 81,908 91% Williston Landfill 18,126 73, % Dickinson Landfill 24,659 44,350 80% McKenzie Co. Lfill 3,650 66, %

5 MSW Facility Challenges Bakken Boom About 250 new permitted waste haulers in western North Dakota; Huge influx of mixed waste loads; Unused Chemicals, Additives, Unused Products, Excess Residues and Partially Full Containers Scrap metal mixed in loads; Pallets and wood; TENORM

6 MSW Facility Challenges Bakken Boom MSW Facilities had difficulty in retaining staff; Health and safety issues for staff; New waste haulers had inadequate, unsafe equipment; Exposure to unknown chemicals and additives; Dwindling landfill capacity; Waste transport staff not adequately trained; Oilfield workers not adequately trained.

7 MSW Landfill Employee Inspecting a Load

8 Equipment No Longer Accepted SAFETY ISSUES

9

10 ALL LOADS WILL BE TESTED WITH A RADIATION DETECTION WAND

11 COMMON TYPES OF OILFIELD WASTE Exploration Waste - Drilling Waste (Fluids and Cuttings) Production Waste Spills - Contaminated Soil

12 Drilling Waste What is it? Drill bit cuttings and solids consisting of bits of rock and sediment circulated out of the well during drilling Discarded drilling fluids or drilling mud Other fluids used or recovered while drilling and completing the well Free fluids are disposed in injection wells Landfills may not accept waste with free liquids

13 PRODUCTION WASTE Production Waste Oil Well Produced Water; Accumulated materials including tank bottoms, from storage facilities, separators, heater treaters, vessels, tanks and production impoundments; Deposits removed from tubular goods, piping, casing, filters, clean-out traps and other equipment; Pigging wastes from gathering lines;

14 Oilfield Exploration and Production Wastes Subject to ND Solid Waste Rules (exempt from HW Rules) Produced water Drilling fluids and drill cuttings Rigwash Well completion, treatment, and stimulation fluids Workover wastes Basic sediment and water and other tank bottom sludge from storage facilities that hold product and exempt waste Accumulated materials such as hydrocarbons, solids, sand, and emulsion from production separators, fluid treating vessels, and production impoundments Pit sludges and contaminated bottoms from storage or disposal exempt wastes Gas plant dehydration wastes, including glycol-based compounds, glycol filters, filter media, backwash, and molecular sieves Gas plant sweetening wastes for sulfur removal, including amine, amine filters, amine filter media, backwash, precipitated amine sludge, iron sponge, and hydrogen sulfide scrubber liquid and sludge Cooling tower blowdown Spent filters, filter media, and backwash (assuming the filter itself is not hazardous and the residue Packing fluids Produced sand Pipe scale, hydrocarbon solids, hydrates, and other deposits removed from piping and equipment prior to transportation Hydrocarbon-bearing soil Pigging wastes from gathering lines Wastes from subsurface gas storage and retrieval, except for the listed nonexempt wastes Constituents removed from produced water before it is injected or otherwise disposed of Liquid hydrocarbons removed from the production stream but not from oil refining Gases removed from the production stream, such as hydrogen sulfide and carbon dioxide, and volatilized hydrocarbons Materials ejected from a producing well during blowdown Waste crude oil from primary field operations and production Light organics volatilized from exempt wastes in reserve pits or impoundments or production equipment

15 CONTAMINATED SOIL Crude Oil Impacted Soil Natural Gas Impacted Soil Salt Impacted Soil Diesel Fuel Impacted Soil Waste Generated from Pipe Leaks, Tank Overflows, Tank Leaks, Stuffing Box Leaks, Reserve Pit Releases, Well Blow-Outs, Tanker Truck Accidents, etc.

16 WASTE CHARACTERISTICS OF CONCERN Bakken and Three Forks Produced Water TDS 256,000 PPM Sodium-Chloride 215,000 PPM Hydrocarbons Benzene, Ethyl benzene, Toluene, Xylene Technically Enhanced Naturally Occurring Radioactive Material (TENORM) Tank Bottom Waste, Pipe Scale, Filter Socks

17 Oilfield Brine Spills Kill Vegetation and Permanently Impact Soils

18 TONS OILFIELD SPECIAL WASTE DISPOSED AT SPECIAL/INDUSTRIAL WASTE LANDFILLS 3,000, ,500, ,489, ,000, ,752, ,500, TONS 1,074, ,000, , , , , YEAR

19 Permitted Oilfield Special Waste Landfills Oilfield Special Waste

20 Permitted Oilfield Special Waste Landfills July Oilfield Special Waste

21 Anatomy of Oilfield Special Waste Landfills Six Inches Topsoil and Grass Compacted Clay under Membrane Liner (Composite Liner) 18 Compacted Clay Cover overlain by 12 Subsoil Waste Monitoring Well Native Clay Soil Drain Pipe Oilfield Special Landfill has 3 foot Composite Liner Leachate System

22 North Dakota Oil Facts April 1951 First producing well October Billionth barrel of oil November Billionth barrel of oil Estimated Billionth barrel of oil May 2012 peak 220 rigs June ,000,000 BOPD December ,124 producing wells 8826 Bakken Three Forks wells March rigs 40,000+ additional development wells

23 Development Phases Phase 1 Discovery - Define productive area Mature Bakken 18,000 square miles

24 Development Phases Phase 3 Harvest in field drilling 6-28 wells per spacing unit

25 Vern Whitten Photography

26

27 Oilfield Waste and TENORM Waste in Landfills 2010 started getting complaints from MSW landfills Oily waste materials, including filter socks Chemical containers and unused chemicals 13 fires in the Williston landfill in 1 year Concerned about radioactive waste Began testing materials with handheld meters Found some filter socks and some proppant to be much greater than background

28 TENORM Regulation in North Dakota Solid Waste rules say no Radioactive Waste allowed in landfills Radioactive Waste means solid waste containing radioactive material subject to requirements of NDAC Article Article 33-10, Radiological Health Rules, does not have a specific set of rules for TENORM Only reference to TENORM is in criteria for vacating premises limit of 5 pci/g Ra in soil or other materials

29 Unused Filter Sock

30 Filter sock found at Williston Landfill

31 Bags of filter socks near Watford City

32 Bags of filter socks in Noonan

33

34 Argonne National Laboratory Risk Study ANL is a recognized world expert on radiation exposure. ANL is an impartial outside party no ties to North Dakota oil industry. Cost $182,000 - paid by NDDH solid waste general funds. None of the funding from oil industry or any other special interest groups.

35 Two-Part Study Primary evaluate whether landfills in North Dakota can safely accept any level of TENORM Secondary evaluate possible TENORM exposure to workers and public even if landfill limit is not changed

36 Landfill Risk Evaluation Maximum TENORM concentration was backcalculated from maximum exposure of 100 mrem/year to the general public Sample data is not necessary for these calculations

37 Landfill Risk Evaluation Scenarios included: Landfill worker situations Resident farmer scenario Intruder scenario Offsite public exposure Groundwater migration for 10,000 years MEI was the daily landfill worker Limit calculated to be 50 pci/g Ra-226 plus Ra- 228

38 Worker and Public Risk Evaluation Several worker and public exposure scenarios were evaluated The study did not include any sample collection and analysis Available sample data was used to give a ballpark range of potential exposure

39 Evaluating Dose in Different Worker and Public Scenarios Mixing hydraulic fracturing fluid Proppant Produced water filtration Filter cake & filter socks Pipe cleaning Scale Storage tank cleaning Sludge Gas processing Pb-210 film Sludge treatment Sludge Filter socks dumped in a dumpster Filter socks Children playing with filter socks Filter socks Children playing in pile of proppant Proppant Truck Transport of Waste Multiple materials

40 Data Limitations Not intended to be a comprehensive study of the full range and variation of TENORM in North Dakota Report acknowledges that sample data is limited Report states that the scenarios are not representative of all possible exposures All real-life situations will be different

41 NDIC Oil & Gas Division Permit Requirement June 1, 2014 Covered, leak-proof containers designated for filter sock disposal On-site at saltwater disposal wells and during the drilling, completion and flow-back phases of all new oil wells. Disposal containers must be collected by a licensed waste hauler and disposed of at an authorized facility.

42 Covered leakproof containers required at SWDs and well sites

43 Containers must be labeled

44 Proposed Rules Radiation Control Program NDAC Chapter Conference of Radiation Control Program Directors (CRCPD) has developed suggested state regulations that address TENORM CRCPD Part N is the model used in developing the TENORM rules for North Dakota Rules establish radiation protection requirements for TENORM

45 Proposed Rules Radiation Control Program NDAC Chapter Licensure required for transporters of TENORM Licensure required for Treatment and Disposal facilities Establish standards for Radiation Protection Establish record keeping and reporting requirements Describes financial assurance requirements Sets out Radiation Safety Officer requirements Outlines worker training requirements

46 Proposed Rules Radiation Control Program NDAC Chapter Proposed rules regulate TENORM, not NORM Materials like drill cuttings and produced water are not regulated under this rule.

47 Proposed Rules Solid Waste Program NDAC Chapter Landfill disposal requirements Maximum 50 pci/g total Ra-226+Ra-228 Maximum 25,000 tons per year Covered by 1 foot of non-tenorm waste or daily cover material each day 10 feet below surface of final cover If final cover slope >15%, then final cover must be at least 5 feet thick

48 Proposed Rules Solid Waste Program NDAC Chapter Leachate and groundwater monitoring are required. Quarterly reporting to the NDDH. Worker training and safety program required. Record of notice attached to property deed will indicate volume of TENORM disposed.

49 Proposed Rules Solid Waste Program NDAC Chapter A rule change in TENORM limit would not automatically increase the limit at all landfills. Will only apply to Special Waste and Industrial Waste landfills. Will not apply to Municipal Solid Waste landfills. Each landfill would have to apply for a major permit modification.

50 Deep well injection of TENORM Underground injection of TENORM is already allowed. Must go into Class II injection well permitted by NDIC, Oil & Gas Division. Will also need NDDH radioactive materials license for the treating/handling area. Several companies are pursuing this option.

51 Rule Proposal Status Public Comment period began 12/12/2014 Extended to 3/2/ Public Comment Hearings held Several hundred pages of written comments NDDH will review and provide written response to all relevant comments Final proposal must be approved by: ND State Health Council ND Attorney General s Office ND Legislative Committee on Administrative Rules

52 Steven Tillotson Ass t Director Div. of Waste Management Manager, Solid Waste Program North Dakota Department of Health stillots@nd.gov NDDoH Waste Management Website: