History + Science + Common Sense =??? Prepared by: W.E. Kennedy, Jr.

Transcription

1 History + Science + Common Sense =??? Prepared by: W.E. Kennedy, Jr. 1

2 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? 2

3 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. 3

4 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 4

5 Definitions History Outline Sources and types of NORM/TENORM Science What we know; what we need to know Common Sense Radiation dose in perspective??? Regulations; the future? 5

6 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) 6

7 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) 7

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9 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 ( s) 9

10 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 10

11 Summary of TENORM Sources EPA Data 2003 Material or Waste Radium Concentration (Bq/g) Low Average High U.S. Soil N/A 0.16 Petroleum Scale <0.009 <7 >3,900 Geothermal Scale Water Treatment N/A 1,600 N/A Filters Coal Bottom Ash Coal Fly Ash Phosphate Ore Titanium Ore Waste

12 Oil Field Waste: Example Radionuclide Radionuclide Content Average Sludge (Bq/g) Average Scale (Bq/g) 210 Po Pb Ra Th Ra Total: 8 49 Note: Typical radium-226 in soil is ~ Bq/g (EPA Data) 12

13 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 13

14 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 14

15 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! 15

16 Pipe Scale q 16

17 Pipe Scale q 17

18 Oil Field Wastes Production Water Production Sludge 18

19 Gas Pipeline Pigging Waste 19

20 TENORM in Pipeline Pigs Measurable radon in natural gas Results in Pb-210; 22 year half-life Po MeV alpha Po is electrostatic Po attaches to rust Potential inhalation hazard 20

21 What is Fracking? 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 21

22 A Brief History of Fracking 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! 22

23 A Brief History of Fracking 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 23

24 A Brief History of Fracking 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 24

25 + 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 25

26 Shale Gas Fracking 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 26

27 Fracking Schematic From USGS 27

28 Current U.S. O&G Surge 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 28

29 Fracking Equipment From USGS 29

30 Drill Rig From USGS 30

31 U.S. Shale Play Locations 31

32 Environmental Issues Water issues Large quantities (15,000 m 3 ) 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 32

33 Fracking Waste Water From USGS 33

34 Special Concerns 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 34

35 PA Study Background 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 35

36 PA Study Background 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

37 PA Study Conclusions 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 37

38 PA TENORM Study Average Results (Bq/g or *Bq/L) Well Sites/Pads 226 Ra 238 U 228 Ra Vertical Cuttings N/A Horizontal Cuttings 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 38

39 Not Just a U.S. Problem U.K present Inspection problem Onshore waste disposal Norway 1985 gas TENORM Pb, Bi, Po-210 Underground disposal 39

40 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 40

41 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 41

42 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 42

43 + 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 43

44 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 44

45 + 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 45

46 ICRP Considerations 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 46

47 Principles: ICRP Considerations 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 47

48 ICRP Recommendations 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) 48

49 IAEA Activities 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

50 IAEA Considerations 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 50

51 IAEA Status 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) 51

52 IAEA Recommendations 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 52

53 IAEA Conclusions 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? 53

54 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 54

55 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 N

56 Comparison of State Limits 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 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 , per facility type Idaho 55 At RCRA Subtitle C landfills 56

57 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 selfregulation? A harmonized approach? 57

58 NCRP SC 5-2 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 58

59 SC 5-2 Membership 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 59

60 Awareness training What s Next? 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! 60

61 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 61

62 Questions? Contact Information: W.E. Kennedy, Jr. (509)