Editor’s Note: Melody Fleck is on the Executive Committee of the Moshannon Group-Sierra Club Executive Committee and is the Committee Chair for Beyond Gas.
On January 15, 2015, the Pennsylvania Department of Environmental Protection (DEP) released its “comprehensive” TENORM Report. TENORM stands for Technically Enhanced Naturally Occurring Radioactive Material, meaning human activity has changed the character of naturally occurring radiation. The 200 page report can be accessed on DEP’s official website.
For more than a year under the Corbett Administration, DEP was collecting information on radioactivity connected to hydraulic fracturing and its byproducts. This past summer, Delaware Riverkeepers Network filed a Right-to-Know request to obtain the information that DEP had collected so that their expert could analyze the raw data. DEP refused to release the information, insisting that release of the “preliminary unvalidated data, including sample locations, could risk harm to the public’s health, pose a security risk . . .and lead to erroneous and/or misleading characterizations of the levels and effects” of the radioactive risks.
The recent TENORM Report is the result of this collection of data and its analysis by DEP. The report uses carefully chosen words to downplay the risk in its Synopsis section. A full reading of the report, and DEP staff admit that it, demonstrates that the public and workers have an increased risk of radiation exposure from the development of natural gas. Radiation risks are present at almost every stage from well drilling, disposal of the enormous waste steam created by the industry, processing, compressing, distribution, storage and use of the gas.
End users of the gas receive 5.2% to 17.8% of their yearly radiation allowance from the use of unvented gas for heating and cooking, according to the report. DEP characterizes this significantly increased risk as a “small fraction” of the allowable yearly dose.
It should be noted that the “allowable yearly dose” is set by federal agencies at the amount that we are likely to receive, not at what is safe. There is no safe level of exposure, according to Dr. Karl Morgan, the “father of Health Physics”. EPA acknowledges, on its website, that even low doses of radiation change blood chemistry. Radiation bio-accumulates in ecosystems and has a cumulative effect in the body, according to the Nuclear Information and Resource Service.
According to the TENORM Report, Marcellus Shale natural gas is laced with Radon-222. The EPA and American Lung Association (ALA) warn that radon causes lung cancer. The EPA & ALA list 21,000 deaths due to radon-caused lung cancer each year in the US and over 221,000 new lung cancer cases are expected to be diagnosed in the US in 2015, according to the ALA’s fact sheet. Lung cancer is the leading cancer killer of men and women; deaths due to lung cancer have increased about 3.5% between 1999 and 2012 (ALA fact sheet).
While Radon-222 has a short half-life as a gas, it decays into radioactive particulate “daughters” over 22 years until it reaches stable lead. The relevance of this fact is that these radioactive particulates coat the inside of distribution lines, trucks, processing equipment, furnaces and appliances. When opened for maintenance and repair, there are potential exposure risks to workers and the public, according to the TENORM Report.
While the report comprehensively covers the processes from drilling to end users, the number of samples collected and analyzed are very sparse for a state-wide study. For example, only 8 well sites were sampled during the flowback phase and of the 8 samples, only 4 had enough volume to analyze. Of 14 drill mud samples collected, only 5 were analyzed as liquids and alpha & beta analysis was only done on one sample. To be fair, Publicly Owned Treatment Works (POTW) were sampled in 3 rounds over 7 months but sediment-impacted soil samples were only collected at 3 POTWs.
Though not exhaustive, here are some additional findings from the report:
- “There are potential radiological environmental impacts from oil & gas fluids, if spilled. Radium should be added to the PA Spill Protocol to ensure cleanups are adequately characterized.”
- “There are site specific circumstances and situations where the use of personal protective equipment by workers or other controls should be evaluated.”
- “Filter cake [particulates that accumulate on filters] from facilities treating oil & gas wastes is a potential radiological environmental impact, if spilled, and there is also a potential long-term disposal issue. TENORM disposal protocols should be reviewed to ensure the safety of long-term disposal.”
- A “limited potential” was found for “recreationalists” using roads treated with oil & gas “brine” from conventional natural gas wells. Further study of the radiological environmental impacts from the use of this wastewater for dust control and de-icing should be conducted. The effects on people who live beside these roads and on crops grown along these roads were not considered in the report. Further testing was recommended.
- There was a significant difference observed in the produced water from conventional and unconventional oil & gas wells. Average Radium-226 was approximately 25 times higher in produced water form unconventional wells.
- For workers, some of the highest exposure rates measured were in the proximity of holding tanks for produced water and wastewater trucks.
- Without including normal background radiation, a POTW workers could get 36.3% of their yearly allowable dose of radiation from their jobs. Individual worker exposure will depend on his/her job and exposure.
- More testing is needed to identify areas of contamination at wastewater treatment plants and landfills and any areas of contamination should be cleaned up.
- The inside surfaces of gas distribution pipe lines and filter housings should be tested to evaluate worker exposure to radioactive accumulated particulates.
Hydraulic fracturing produces an enormous stream of waste by-products. Safe disposal practices for the waste has not been devised. From 2007-2011, according to James M. Silva, produced water was being sent to POTWs, at which time, DEP asked the production companies to voluntarily cease this practice. Since 2011, produced water is supposed to be sent to Class II disposal sites, such as the one in Youngstown, Ohio. Lately, a connection has been made between this type of disposal and earthquakes.
Currently, DEP allows radioactive waste from oil & gas to be deposited in landfills at a 1:50 dilution ration. About 12 of Pennsylvania’s 50 landfills accept such waste. The dilution theory does nothing to render the waste safe, it just requires the radioactive waste to be mixed with other garbage so the radiation in each truckload is not too high. In 2011, 449,573 tons of radioactive waste entered PA landfills. In 2014, 430,317 tons of radioactive waste were deposited in PA landfills in the first 10 months of the year. The TENORM Report recommends “considering” limiting radioactive effluent discharge from landfills and adding Radium-226 and Radium-228 to annual sample analysis of leachate from landfills.
According to Dr. Marvin Resnikoff, an international expert on radiation, drilling companies and geologists locate the Marcellus Shale layer by its higher level of radiation. An article by Kenneth Kemow, PhD, indicates that Marcellus Shale has 20 times higher emissions than other uranium deposits (from “Geology”, a PA Department of Conservation and Natural Resources publication, 2012). US Geological Survey research geologist, Mark Engle, has stated that the concentration of Radium-226 (a decay product of uranium) can exceed 10,000 picocuries per liter in the concentrated brine trapped in the shale depths. 23 years ago, DEP’s NORM Survey (1992) also found elevated radioactive Radium-226 and Radium-228 in oil & gas brine samples.
Penn State’s Marcellus Shale Center for Outreach tells us that Marcellus Shale is 2,000 to 9,000 feet underground. It is shielded by dense layers of rock and underground water tables. Most people don’t need a study to logically conclude that bringing radioactive material to the surface and into contact with people and ecosystems will increase the risk. Now there is a government study to underscore this logic. But more needs to be done.
What can you do? Get involved and educated about hydraulic fracturing, share information with your friends and neighbors, and take an active role in influencing our legislators, DEP and Governor Wolf. There is an opportunity for public comment on Chapter 78 Oil & Gas Regulations until May 19th. Please visit DEP’s website to see how to submit your comment.
