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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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