Disposal of Oil & Gas Waste. NYSBA Environmental Section Fall Conference 2015
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1 Disposal of Oil & Gas Waste NYSBA Environmental Section Fall Conference 2015 Larry Shilling October 3, 2015 CASELLA RESOURCE SOLUTIONS ZERO- casella.com 1
2 CASELLA RESOURCE SOLUTIONS ZERO- casella.com 2
3 CASELLA FOOTPRINT -to-energy CASELLA RESOURCE SOLUTIONS ZERO- casella.com 3
4 Marcellus Waste Types of Waste where does it come from Casella Investigations what we found Volumes how much we accepted in 2013 Other considerations CASELLA RESOURCE SOLUTIONS ZERO- casella.com
5 Marcellus and Utica Outcrop CASELLA RESOURCE SOLUTIONS ZERO- casella.com 5
6 from CASELLA RESOURCE SOLUTIONS ZERO- casella.com 6
7 Solid Waste - Sludge Sludges or filtrate, from treatment of Produced Water May come from general WWTP or from facilities specifically built for the treatment or recycling of frac fluids and produced water. May have higher levels of NORM material CASELLA RESOURCE SOLUTIONS ZERO- casella.com
8 Solid Waste Contaminated Soil / General Waste An increase of activity of any kind will likely produce more spill incidents, leading to additional contaminated soil. There will be pad liners and de-construction waste from the well sites CASELLA RESOURCE SOLUTIONS ZERO- casella.com 8
9 Solid Waste Pads and Ponds Liner material and cleanup waste will likely come from the demolition of water storage ponds and pad size reductions. CASELLA RESOURCE SOLUTIONS ZERO- casella.com
10 Solid Waste Drill Cuttings CASELLA RESOURCE SOLUTIONS ZERO- casella.com 10
11 Solid Waste Drill Cuttings Drill Cuttings mostly fine particles of rock and shale mixed with small amounts of drilling fluids There are generally 2 types of drilling fluid; Water and air are used to drill the first vertical section of the well, far below any fresh water zones, sometimes for the entire vertical portion of the well. Some drillers switch to a Synthetic Oil based mud at the beginning of the turn, through the horizontal leg CASELLA RESOURCE SOLUTIONS ZERO- casella.com 11
12 Solid Waste Drill Cuttings Prior to shipping, drill cuttings can be mixed with a bulking agent, Cement kiln dust, lime or sawdust to increase the percent solids to 50% - 60%. CASELLA RESOURCE SOLUTIONS ZERO- casella.com 12
13 Waste and Landfill Impact Studies In 2009, the information on Marcellus waste was not well known. Not much information was available, anywhere. The greatest concern was radioactivity. Casella is responsible for the integrity of the facility forever and needed to confirm potential risk. Casella Phase 1 investigated the actual Radium concentration in drill cuttings. Casella Phase 2 modeled the long term impact of drill cuttings on landfills. CASELLA RESOURCE SOLUTIONS ZERO- casella.com 13
14 Casella Phase 1 Hired expert in radiological science to evaluate and test Marcellus drill cuttings. Acquired Marcellus drill cutting samples directly from drill rigs at known depths. Gathered samples from native soils around landfill and cuttings as delivered to landfills. Samples confirmed by expert geologist. CASELLA RESOURCE SOLUTIONS ZERO- casella.com
15 Casella Phase 1 - Results NORM Naturally Occurring Radioactive Material Average concentration of Radium 226 in on site soils was 0.9 pci/g Average for drill cuttings was 2.1 pci/g EPA standard for radium at the surface for uranium mill cleanups is 5 pci/g for un-restricted use such as a hospital or elementary school Fire brick tested 4.3 pci/g Sandblast media tested 19.1 pci/g CASELLA RESOURCE SOLUTIONS ZERO- casella.com 15
16 Casella Phase 1 CASELLA RESOURCE SOLUTIONS ZERO- casella.com 16
17 Casella Phase II Transport of Ra 226 to Leachate Casella study followed ANL protocol Modeled high, medium and low volumes and concentrations in materials disposed of at landfill Results indicate that at the high volume and high concentration,(50 pci/g), no appreciable impact to leachate or workers would result. Best Management Practices include; Keeping a 6 foot separation from drill cuttings and leachate collection systems Keeping a 10 foot separation from the final cap CASELLA RESOURCE SOLUTIONS ZERO- casella.com
18 Precautions Radiation Detectors installed at all 3 sites in Every load goes through. Detectors at Chemung have alarmed 3 times, all related to medical treatments. Not once have they alarmed for drilling waste. Drill cuttings are accepted following our Industrial Waste protocol and tested prior to acceptance. Leachate is tested for radioactivity on a regular basis. CASELLA RESOURCE SOLUTIONS ZERO- casella.com 18
19 Casella s Drill Cuttings Acceptance Protocol Casella has voluntarily implemented a procedure to prevent radioactivity exceedances: Installation of radioactivity monitors which would detect radioactivity in waste trucks Limit of 25 pci/g annual average, 50 pci/g for any one truckload for facility Trucks are stopped if higher than 15 pci/g are detected These levels are designed to prevent exceeding the recommended dose of radiation for residential and agricultural uses nearby All trucks have to stop at weigh house and proceed slowly through detectors. Alarm sounds if there is an exceedance of radioactivity above 15 pci/g. State and local officials, and DEC notified if alarm is triggered, truck stopped and material investigated. No exceedances from oil and gas waste from any of Casella s landfills Leachate sampling also required to ensure radioactivity levels remain low and suitable for POTW treatment. CASELLA RESOURCE SOLUTIONS ZERO- casella.com
20 Leachate Radioactivity Results CASELLA RESOURCE SOLUTIONS ZERO- casella.com 20
21 NYSDEC Administrative Proceedings DEC reviewed and approved acceptance of drill cuttings using same process as other industrial wastes. DEC further evaluated it as part of an administrative proceeding relating to an increase in the tonnage accepted at the Chemung County Landfill: CASELLA RESOURCE SOLUTIONS ZERO- casella.com 21
22 Chemung County Issues Ruling In the Matter of Chemung County, Issues Ruling, Dated September 3, 2010 (2010 WL ) Proposed intervenor raised issue of disposal of drill cuttings at Chemung County Landfill as an issue for adjudication Proposed expert testimony regarding radioactivity prepared CASELLA RESOURCE SOLUTIONS ZERO- casella.com 22
23 Chemung County Issues Ruling ALJ found no adjudicable issue because: Drill cuttings previously studied & approved by DEC Drill cuttings are not being added to the waste stream as part of the subject modification The issue of drill cuttings is unrelated to the permit modification CASELLA RESOURCE SOLUTIONS ZERO- casella.com 23
24 In the Matter of Chemung County, Commissioner s Decision dated August 4, 2011 (2011 WL ) : -Affirmed the ALJ s ruling, finding: Drill cuttings are a permitted waste for Part 360 landfills Sampling completed was sufficient Drill cuttings are the only drill waste that may be accepted without specific NYSDEC approval.. CASELLA RESOURCE SOLUTIONS ZERO- casella.com
25 Chemung County Commissioner s Decision Commissioner directed that DEC evaluate certain issues to determine if permit conditions were necessary, including: Ensuring only suitable wastes are accepted Set appropriate radiation detection limits in the monitoring system Include proper disposal practices for drill cuttings and leachate management CASELLA RESOURCE SOLUTIONS ZERO- casella.com 25
26 Recent NYSDEC Guidance NYSDEC sent letters out September 18, 2015, to all landfills accepting Oil & Gas waste. Letter confirms the protocol we developed for Chemung would be followed statewide, with one change. Rather than allowing an average of 25 pci/g, NY Landfills will not accept any material over 25 pci/g. CASELLA RESOURCE SOLUTIONS ZERO- casella.com 26
27 Volume into Landfills 2013 Drill Cuttings Total Waste Hyland 1, ,303 0% Hakes 14, ,930 6% Chemung 67, ,177 30% Total 83, ,410 12% CASELLA RESOURCE SOLUTIONS ZERO- casella.com
28 Conclusions 1. The protocol we helped develop is now being used statewide. 2. Detectors are sensitive enough to detect very small amounts of radioactivity. 3. Leachate testing has shown that radioactivity is orders of magnitude below the discharge limits to a stream. 4. Drill Cuttings are not fracking waste. 5. There have been no measurable negative impacts from disposal of drill cuttings in our landfills. CASELLA RESOURCE SOLUTIONS ZERO- casella.com 28
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