The Facts on Fracking (Part 1) - Fracking Waste Management

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Fracking Waste Streams in Ohio
July 11, 2013

Melanie Houston
Ohio Environmental
Council
Teresa Mills
Center for Health,
Environment & Justice &
Buckeye Forest Council
Julie Weatherington-Rice
Bennett & Williams Inc. &
The Ohio State University
Fracking Waste Streams in Ohio
July 11, 2013

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What is Hydraulic Fracturing?
“Hydraulic Fracturing is a well stimulation process
used to maximize the extraction of underground
resources” (EPA)
Fracking is the process of using explosive
charges, followed by the injection of millions
of gallons of water, sand, and chemicals to
break up rock miles beneath the surface of
the earth. Horizontal drilling allows shale gas
or shale oil to be extracted and pumped to the
surface, along with the fluid used in the drilling
operation. (University of Connecticut)

General Oversight & Regulation
 Notification and reporting requirements during
cementing, well completion, well stimulation and well
production (ODNR)
 Site restoration is required for urban and non-urban area
well sites (ODNR)
 Water withdrawal: the law requires registration if a facility
has the capacity to withdraw 100,000 gallons per day
(ODNR)
 Air: permit-to-install and operate required for units or
activities that emit air pollutants (Ohio EPA)
 Radioactivity: solid waste disposal (ODNR, Ohio EPA, ODH)
*Source of information: Ohio’s Regulations: A Guide for operators drilling in the Marcellus & Utica
Shales. Ohio EPA. March 2012.

What are shale gas waste streams?
 Brine: Salt water (EPA)
 Flowback fluid: Recovered fracturing fluids, also called produced
water (EPA)
 Drilling mud/fluid: A mixture of liquids and gaseous fluids and
mixtures of fluids and solids used to drill into the earth. (Oilfield
Glossary)
 Note: All three also likely to include fracking chemicals, heavy metals &
radiological materials
Flowback Fluid

More Fracking Terms
 Drill cuttings: Rocks and soil that are brought to the surface during
drilling activity (US EPA)
 Pipe scale: Material that builds up on the inside of pipes. This
material makes the inner area of the pipe smaller, which increases the
pressure inside the pipe. (US EPA)
Pipe ScaleDrill cuttings in an open pit

Temporary Storage for Fracking Wastes
 Impoundments: are used to contain millions of gallons of water
and recycled natural gas drilling wastewater. (Marcellus-Shale)
 Open Pits: holds fracking fluids and drill cuttings, may be lined, but
can overflow and leak into the soil (OSHA)
Impoundment dam in PAOverflowing open pit

Shale Gas Wastes from the
Marcellus and Utica Shales: what
are they & how are they managed?
Julie Weatherington-Rice, PhD, CPG, CPSS
Bennett & Williams Environmental
Consultants Inc.
An Ohio Fracture Flow
Working Group Presentation
July 12, 2013
Adj. Asst. Prof,
Ohio State U.
Food, Ag & Bio Eng.

Radioactivity in Black Shales –
where does it come from?
• We are Stardust
• So is everything around
us, including black
shales
• Hydrogen to Boron
formed in the Big Bang
• Carbon and all the rest
form during the life of a
star & are released at
it’s death – a Supernova

Black Shales are Radioactive
two ways
• From their parent source
rocks
• Devonian Marcellus –
Appalachian uplifts
• Silurian Utica – earlier
mountain building &
Canadian Shield
• From Bioaccumulation
• Black shales and coals are big,
dirty, old activated carbon filters
• As surface & ground water
carrying soluble heavy &
radioactive metal cations move
through the shales, the organic
carbon, a very strong negative
magnet, releases small & light
cations and binds bigger &
heavier cations
• The older the rock & higher the
carbon content, the more the
radiation, sources being equal
• The higher the sources, the more
the radiation

2013 Focusing on Shale Gas Wastes
• Ground Shale Rock: hydrocarbons, heavy &
radioactive metals, Ohio–NORM, US EPA-TENORM
• Drilling Muds & Sludges: who knows what,
TENORM
• Fracking Fluids: water, sand, who knows what, if
recycled, are they-NORM, US EPA-TENORM
• Brine: salts, hydrocarbons, heavy & radioactive
metals, Ohio-NORM, US EPA-TENORM
• Drilling Site Wastes & Accidental Releases:
who knows what is being released
• Where are they coming from?
• Where are they going?

Why the NORM – TENORM
Confusion?
• Four National Definitions for NORM-TENORM
• Ohio uses Conference of Radiation Control
Program Directors, 1990, least restrictive
• US EPA, Nat. Academy Sci and ANSI all add to
NORM “potential for increased exposure” making
whole waste stream TENORM & subject to testing
• 5 pCi/g (US EPA clean-up standard) & 5 pCi/L (US
EPA Drinking Water MCL) would apply to whole
waste stream*
• * pCi/g or L, picoCurie/gram or Liter

• Ohio has paid for State & Local governments
by taxing (tipping fees, etc.) out of state waste
streams (solid, C&DD, industrial, medical, O&G, etc.)
for last 20+ years
• Shale Gas drilling has created a big, new
waste stream not addressed by surrounding
states - seen as a new & easily captured revenue
source by Ohio’s Administration
• Ohio DOES NOT have magic GEOLOGY
– that can swallow all wastes without repercussions
Why the Current Concern?

Why the Current Concern Cont?
• Blacks shales are early sources of Uranium ore
for the “Atomic Age” (Chattanooga Shale, TN; USGS,
1961)
• Black shales like coal are full of heavy and
radioactive metals: 232Th to 228Ra & 238U to 226Ra are
most common series
• 228Ra, 238U & 226Ra water soluble, also in brines
• US EPA limit on Uranium mill tailings, 5 pCi/g
because of the Radium: > LLRW Landfill, Utah or
Washington State accept NORM
• US EPA Drinking Water MCL 5 pCi/L for Radium

Figure 1. Graph from Radioactive Elements in Coal and Fly Ash:
Abundance, Forms, and Environmental Significance. U.S. Geological
Survey Fact Sheet FS-163-97. October, 1997

Why the Current Concern Cont?
• NY brine up to 15,000 pCi/L
226Ra
• Hard scale in used drilling
pipes up to 6,000 pCi/g 226Ra
and up to 2,000 pCi/g 228Ra –
requires TENORM handling
• Ohio still contaminated
from the Manhattan
Project
– we know better now

Radioactivity = TOC = Gas
• Gamma Ray
signature shows
highest levels of
radioactivity in the
shale
• Horizontal laterals
installed in hottest
zones
• Shale cuttings are
from hottest areas

5 pCi/L MCL: Why the Health Risk?
Because water-soluble Radium replaces Calcium in
your bones if you drink it, Pb-210 also a bone seeker
WhataboutK-40?

Shale Gas Wastes: A Growth
Industry for Ohio
• Wastes coming into Ohio by road, rails &
soon by river barge, port Washington Co.
in place
• Over 52% 2012 injections in Class II
wells came from out of state, mostly PA &
WV
• Dedicated out-of-state Class II wells
being installed in SE Ohio (new one
Athens Co.)

Industry for Ohio cont.
• No Public Hearings being held for anyone
• With NY still to be decided & barge ports
for Ohio River/Gulf wastes coming on line
– may be up to 80% out of state wastes in
a few years
• Ground Shale Rock with drilling muds to
Solid Waste and C&DD Landfills; no
records of how much or where, just listed
as “solid wastes”; used as daily cover, not
buried

• All Fracking Fluids & Brines to be
injected in Class II wells except when
spread on roads (brines), “solidified”
and put in landfills or other
management processes yet to be
determined
• ODNR Div. Oil & Gas Resources calls the
shots; OEPA and ODH are second
Industry for Ohio cont.

Drillers: Ohio easy place to do
business in (Cols Dispatch, 5-1-13)
• “Ohio is probably the most regulatory-
friendly state I’ve operated in”, Randy
Albert, Consol Energy, PA
• “To its credit, DNR has sought more
regulatory power over this industry”, Jack
Shaner, Ohio Environmental Council
• “But some of those attempts have met
resistance from majority Republicans in
the Ohio General Assembly”, Dan Gearino,
Cols Dispatch

Injection wells
Teresa Mills
Center for Health, Environment and Justice
And
Buckeye Forest Council

The Facts on Fracking (Part 1) - Fracking Waste Management

What does a Class II injection well
look like?

Injection well-Knox County Channel 4 News
Older injection well

Injection Well 1st Step:
Surface Casing
• Surface casing is the first casing installed in
the well. A hole is drilled from the surface to
below the base of the lowest aquifer. The
surface casing is installed in the borehole, and
is sealed into the hole with cement.
• Cementing is the introduction, usually from
the bottom-up, of neat Portland cement (not
concrete) and mineral additives, that serve to
seal the casing to the formations exposed in
the borehole.

2nd Step: Long-String
Casing
• Long-string casing is installed within the
surface casing -imagine a pipe within a
pipe. The cementing plug is drilled out and
drilling continues through the confining
zone to the injection interval. The long-
string casing is installed from the surface
to (or through) the injection zone, and is
sealed into the drill hole with cement.

3rd Step: Injection Tubing
• Tubing is the smallest diameter pipe in the well. Tubing is installed inside the long-string
casing, and carries the injectate from the surface to the injection zone. It is usually constructed
of corrosion-resistant steel or fiberglass-reinforced-plastic, and is typically 2-1/2 to 7 inches in
diameter.
• The packer is a mechanical device that seals the outside of the tubing to the inside of the
long-string casing, near the bottom of the tubing.
• The wellhead seals the gap between the tubing and long-string casing, at the top of the
tubing.
• The packer annulus is the space between the outside of the tubing and the inside of the
long-string casing. The annulus is sealed at the top by the wellhead, and at the bottom by the
packer. Pressure can be maintained on the annulus, and monitored by the injection well
operator. Any change in pressure indicates a leak in the system. An analogy is the pressure
you maintain on the annulus of your automobile tires. A flat tire indicates a defect in either
the tire or the rim. Similarly, monitoring the annulus pressure provides a continuous
measurement of the internal integrity of an injection well.

8 5/8 inches
4 ½ inches
2 3/8 inches
Injection
tubing
Annulus
Cement
Less than 2
inch radius
of cement
around
long string
Less than 1 inch radius of
fluid around injection tubing

Only 50 feet below drinking
water source

Safe Drinking Water Act (SDWA)
The Safe Drinking Water Act (SDWA) is the main federal law that ensures the
quality of Americans' drinking water. Under SDWA, EPA sets standards for
drinking water quality and oversees the states, localities, and water suppliers who
implement those standards.
SDWA was originally passed by Congress in 1974 to protect public health by
regulating the nation's public drinking water supply. The law was amended in 1986
and 1996 and requires many actions to protect drinking water and its sources:
rivers, lakes, reservoirs, springs, and ground water wells.

– Supplies any public water system or contains a quantity of
ground water sufficient to supply a public water system
(SDWA does not regulate private wells which serve fewer than 25 individuals.)
PUBLIC

So how did we get where we are today?

In 1974, responding to concerns about underground injection practices, including
failure of some wells, the U.S. EPA raised concerns that injected waste could
contaminate underground drinking water.
In December 1974, Congress enacted the Safe Drinking Water Act, which required
the EPA to set requirements for protecting underground sources of drinking water.
EPA passed its Underground injection Control regulations in 1980.
In 1988 EPA made its UIC regulations stronger to comply with the newly upgraded
waste disposal amendments of the Resource Conservation and Recovery Act.
In 1988 EPA exempted E&P waste from oil and gas from requirement under
Subtitle C of RCRA.

In its 1988 Regulatory Determination, EPA admitted that E&P
wastes contain toxic substances that endanger both human health
and the environment. Despite noting that benzene, phenanthrene,
lead, arsenic, barium, antimony, fluoride, and uranium found in
E&P wastes were of major concern and present at “levels that exceed
100 times EPA’s health based standards,” EPA declined to regulate
these toxic substances under Subtitle C of RCRA.
EPA identified three factors as the basis for its decision not to
regulate E&P wastes under Subtitle C. These factors included:
(1) the infeasibility of implementing alternative regulations,
(2) the adequacy of state regulations,
(3) the economic harm that would befall the oil and gas industry if
additional regulatory controls were imposed

Recycling of Fracking Fluids
• Chesapeake in Carroll County, Ohio
• Range Resources in PA
• Consol/Epiphany/PMC Biotech solar
powered recycling pilot plant started
in July 2012 in PA
• Number of others as well
Why? Because they need the water for the
next well & savings on reclaimed
chemicals

Potential Problems from Recycling
• Recycled fracking fluids need to be filtered
– to remove sand, rock cuttings, etc. before being reused
• Filtered materials go to landfills
• Reusing the fluid increases the levels of
Radium each time through, not removed
• Eventually TDS etc. so high that fluid must
be disposed of in Class II wells anyway
• Ohio not collecting information on Recyclers
– who/where they are, how they collect fluids, how dispose of
wastes, etc.

The Patriot Water Treatment /
Warren, Ohio WWTP Process
• Fracking flowback water is trucked to the Patriot
Facility in Warren
• Flowback is filtered & blended & sent to Warren
WWTP where discharged to Mahoning River
• Where does filter cake go?
• Patriot & Warren WWTP check for radium w/
handheld monitor which underreports
• OEPA says ODH approved, ODH says ODNR
approved, ODNR not qualified to approve
radiation monitoring or managing of WWTPs
• No one knows how much radium is being
discharged into the Mahoning River at Warren

Our Studies Show Real-Time
Measurements at Landfills & WWTPs
are Unreliable
Radium emits alpha &
beta, not a strong
gamma emitter
Requires Ra-226 to Rn-
222 to Po-218 to Pb-214
or Bi-214 decay to get
good measure
Standard is 21-days
holding time in sealed
jar in lab for reliable
levels

Repurposing of O&G Brine
• Almost everything in O&G brine has an
industrial application & a current
market
• Already “mine” salts in Ohio for
industrial applications
• DOE/GE working on process to remove
Radium-228 and 226 from brine
• Technology already exists to break
O&G brine down, working on
economics

Repurposing of O&G Brine cont.
• Why dispose of resources we need &
would have to make/extract in other
ways for other costs?
• Ohio could still extract “tax” for out-
of-state brine if reprocessed here,
real jobs for Ohio

Legal disposal for shale
rock cuttings, drilling
muds and associated
wastes
Am. HB 59 requires
downblending if Ra
levels above MCLs for
TENORM only, NO
TESTING for NORM
No requirement that
chemical binding of
radioactive materials to
dilution materials must
occur
Landfilling the Wastes

But are they Low Level
Radioactive Waste Landfills?
• No solid waste and
C&DD waste
landfills in Ohio
meet our siting &
design criteria for
LLRW disposal
• OSU Extension
Research “Low-
Level Radioactive
Waste Fact Sheet
Series” (RER-00)
explains why
Cement vaults above ground, wastes
drummed, over packed and sealed
Ohioline.osu.edu/rer-fact/

How Long to Protect from Human
Interaction if We use Michigan’s 50
pCi/g Landfill Limit
• 50 pCi/g to 25 pCi/g to 12.5 pCi/g to 6.25 pCi/g to 5
pCi/g: 3+ half-lives
• 50 pCi/g Radium-226 to 5 pCi/g ~5,000 yrs, back to
the beginning of Egypt's pyramids
• 50 pCi/g Uranium-238 to 5 pCi/g, 3+ half-lives, back
to the beginning of the Universe
• 50 pCi/g Thorium-232 to 5 pCi/g, ~45 Billion years,
more than the diameter of the visible universe

Other Solutions for Brine Disposal
Sure to Reach the Water
Use for deicing on
winter roads
still legal in parts of Ohio
Dump it down a storm drain!
Ben Lupo, president D&L Energy/Hardrock
Excavation admits to at least 250,000
gallons of brine & oil-based muds dumped
into the Mahoning River, 2012-2013
No one told Beaver Falls, PA

Big Picture: Waste of the
Resource• Black Shales long known to be a
source of both uranium and oil
• Early development of western
black shales used heat/retort
method of extracting oil, also
expanded volcanic clays to 40%
more volume than original
materials
Swanson, 1960

Resource, cont.
• Efforts were made to retort in place, also less
than successful
• Three efforts in the early 1970’s using
underground detonations of nuclear bombs
also proved to be unsuccessful and rendered
gas too radioactive to use
(http://en.wikipedia.org/wiki/Operation_Plows
hare)
• Hydraulic fracturing is just the latest attempt
to extract oil & gas from tight black shales

Resource, cont.
Approximately 6 ½% of
resource recovered with
each frac
Shale wells notorious for
short production time
Each refrac produces
less results
JD Hughes, 2013, Nature vol. 494

Ohio has been
down this path
before
• 1890’s, the Lima-Findlay oil field;
Trenton LS / Utica Shale
• J D Rockefeller & Standard Oil
• Drilled so many holes depressured the field
• Up to 90% of reserve still in the ground
• Cost a fortune to recover it now

New Paper Ohio Journal of
Science – this fall
• Drilling the Utica & Marcellus Shales in
Ohio
• What we know, what we don’t know
• Environmental & legal issues/controls
• Public health considerations
• Socio-economic considerations
• 11 authors, multiple backgrounds
• Ohio Journal of Science Web Link at OSU,
https://kb.osu.edu/dspace/handle/1811/686

Contacts for this presentation &
Ohio Journal of Science Papers
OFFWG, Dr. Julie Weatherington-Rice, B&W, OSU FABE,
weatherington-ri.1@osu.edu
OFFWG, Dr. Ann Christy, OSU FABE, christy.14@osu.edu
Bennett & Williams, Linda Aller RS,
Laller@bennettandwilliams.com
Ohio Journal of Science Web Link at OSU,
https://kb.osu.edu/dspace/handle/1811/686
Ohio EPA Division of Drinking and Ground Waters Source Water
Assessment and Protection Program,
www.epa.ohio.gov/ddagw/swap_ssa.aspx
Keeping Ohio’s Water Clean
Ohio Fracture Flow Working
Group

The Facts on Fracking (Part 1) - Fracking Waste Management

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