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

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Fracking Waste Streams in OhioJuly 11, 2013

Melanie HoustonOhio Environmental Council

Teresa MillsCenter for Health, Environment & Justice & Buckeye Forest Council

Julie Weatherington-RiceBennett & Williams Inc. &The Ohio State University

Fracking Waste Streams in OhioJuly 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

Wh

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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.)

Shale Gas Wastes: A Growth 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

Shale Gas Wastes: A Growth 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

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 stringLess 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 UnreliableRadium 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 NORMNo 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

Big Picture: Waste of the 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_Plowshare)

• Hydraulic fracturing is just the latest attempt to extract oil & gas from tight black shales

Big Picture: Waste of the 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, [email protected]

OFFWG, Dr. Ann Christy, OSU FABE, [email protected] & Williams, Linda Aller RS,

[email protected] 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 CleanOhio Fracture Flow Working

Group

Q&A