TENORM and Shale Oil & Gas Considerations for State Programs National Governors Association State Policy Forum on Responsible Shale Energy Development Pittsburgh, Pennsylvania Presented by: Dan Schultheisz U.S. Environmental Protection Agency Office of Radiation and Indoor Air
What is TENORM? Industries that utilize natural resources often unintentionally concentrate naturally occurring radioactive material (NORM) in their products or wastes. Focus is on uranium and thorium series isotopes (~1-3 ppm in Earth s crust). When concentrated as a result of human activity, or relocated such that there is opportunity for radiation exposure, the residual material is called TENORM (technologically-enhanced NORM). EPA working definition Examples of Impacted Industries Drinking water and wastewater treatment Oil and gas Hard rock mine tailings and overburden Rare earths Geothermal Coal combustion byproducts Phosphogypsum 2
Oil & Gas Sector TENORM has been a challenge for this sector for years (e.g., pipe scale build-up, waste management). What s new? Horizontal drilling and fracking allows industry to access black shale deposits that have more uranium and thorium than traditional reservoirs. Fracking the shale involves injecting large volumes of water into the formation and it produces more waste than traditional exploration and production (E&P). When that water comes back up, it brings with it radium and radon (plus progeny) that has been trapped in the formation TENORM. Up to 6 million gallons of water used to frac one well: managing large volumes of contaminated water is challenging. 3
How is TENORM regulated? Federal Perspectives NORM/TENORM is not regulated in the same federal framework as other radioactive materials or wastes. NORM/TENORM is NOT regulated under the Atomic Energy Act (AEA): AEA scope is limited to source, special nuclear, or byproduct material. While the same isotopes may be involved, TENORM by definition is not commercial radioactive waste. TENORM can be (and is) regulated as solid waste under RCRA and as a CERCLA hazardous substance. TENORM can also be subject to the Clean Air Act (CAA), Clean Water Act (CWA) and/or Safe Drinking Water Act (SDWA). However, there are limitations to application of these federal statutes. 4
How is TENORM Regulated? State Perspectives States have the overall authority and lead to address TENORM. State Oil and Gas Conservation Commissions (OGCC) have authority for E&P drilling operations (~35 States). State Environmental/Health Departments have authority over commercial operations (e.g., treatment facilities, brine pits) taking from more than one entity. Fewer than one-third of states have TENORM regulations typically based on Conference of Radiation Control Program Directors (CRCPD) model regulation. 5
US shale plays 6
What Does TENORM Look Like? Contaminated equipment Pb-210/Po-210 scale Contaminated sock filters Radium pipe scale Brine disposal pits Super sacks of soil 7
State Regulatory Challenges Address the multi-media nature of TENORM Waste acceptance criteria for landfills. Storage and discharges of liquid effluents. Cleanup levels. Landfarming/dust suppression. Radon in natural gas. Approaches vary, depending in part on whether TENORM results from in-state production (e.g., Pennsylvania, North Dakota). Concerns are primarily driven by import of waste from producing states (e.g., Ohio, Michigan, West Virginia, Kentucky). Coordination between radiation control, environmental, and oil and gas programs often located in different departments. 8
Logistical Challenges Management of water, drill cuttings, sediments, sludges, filters, scales, contaminated material and equipment. Drill cuttings and brine may or may not be TENORM depending on the definition used; NORM is generally not subject to sampling: Very limited data for spills. Some states consider cuttings unregulated NORM. Much is recycled, reused or injected: Radioactivity is not necessarily removed during treatment prior to reuse, resulting in radioactivity being injected into wells along with chemicals. Eventually the radioactivity must be controlled and managed this can be done responsibly and safely to limit potential exposure situations. 9
Be Aware of These Aspects Land Application: Fluids used for dust suppression on roads, discharged to surface waters, landfarming and landspreading. No beneficial attribute with respect to radioactivity. Can constitute a chronic hazard over time. Not tracked like biosolids. Radon: Collected or vented along with gas. Limited data to evaluate potential impacts to environment or end-user. Potential impacts to workers may be most significant concern radon decay produces radioactive isotopes of lead and polonium in equipment. 10
Recent State Efforts to Evaluate TENORM Pennsylvania comprehensive study of TENORM associated with unconventional gas production (Marcellus Shale). North Dakota commissioned Argonne National Laboratory study on waste products resulting from oil production supports new regulations for landfill disposal (Bakken Shale). CRCPD E-42 Task Force review of TENORM in the oil and gas industry. And One Non-State Current Effort National Council on Radiation Protection and Measurement (NCRP) Scientific Committee 5-2 on radiation protection for NORM/TENORM from oil and gas recovery. 11
Example Concentrations Flowback water: USGS reports up to 19,000 pci/l Ra-226. Pennsylvania reports up to 26,000 pci/l Ra-226. Rates of flow and concentrations are heterogeneous within a well and within the play. Scales, sludges, sediments, filters: Ra-226 scales up to hundreds of nci/g (Half-life of Ra-226 is 1,600 years.). Pb-210/Po-210 up to millions of dpm/100 cm² - Orders of magnitude above any regulatory limit or guideline (e.g., ANSI N13.12 clearance limit for Po-210 is 600 dpm/100 cm²). Points of comparison: Drinking water MCL is 5 pci/l combined Ra-226/228. Cleanup standard (uranium mill tailings) is 5 pci/g Ra-226. 12
Questions? For more information, contact Phil Egidi U.S. Environmental Protection Agency Radiation Protection Division Center for Waste Management and Regulations Phone: (202) 343-9186 Email: Egidi.Philip@epa.gov 13