|Road spreading Marcellus well brine in PA (photo provided)|
New York's proposed hydrofracking regulations mention NORM (naturally occurring radioactive material) in section 560.7 Waste Management and Reclamation. According to the new regs, flowback fluids “must be tested for naturally occurring radioactive material prior to removal from the site”. Soils adjacent to tanks storing flowback and production brine must be measured as well.
But there is no requirement to track any radioactive waste fluids – nor is there anything requiring drilling companies to prevent the release of these radioactive substance into the environment in the first place – something Sandra Steingraber notes in today’s entry at 30 Days of Fracking Regs. As she notes, radioactive waste could be stored as close as 500 feet to a home or school, possibly closer to playgrounds and soccer fields, and definitely much closer to barns, pastures and fields where our food is grown.
Four years ago the NY Department of Environmental Conservation (DEC) submitted 13 brine samples from twelve actively-producing Marcellus wells. Test results (appendix 13) showed that some brines had levels of radium-226 as high as 250 times the allowable level for discharge into the environment and thousands of times higher than the maximum allowed in drinking water.
Radioactivity in Marcellus shale shows up as trace elements uranium-238, thorium-232, radium-222, radium-226, and radium-228. Over time these radioactive particles decay, with half-lives anywhere from 4 days to 1600 years. Exposure to some radionuclides – even at low levels – can cause bone cancer, stomach and lung cancers and other health problems. Radon gas, long known to be associated with Marcellus shale, has been shown to be the primary cause of lung cancer among people who have never smoked. So the Environmental Protection Agency (EPA) has established guidelines for certain radionuclides: the maximum contaminant level of radium in drinking water as 5 picocuries per liter (pCi/L), for uranium is 30 pCi/L and for the total alpha emitters is 15 pCi/L. They've also established levels that can be put into the environment: the maximum level of radium-226 allowed to be discharged in wastewater is 60 pCi/L and the maximum levels in soil are 5 pCi/g on the surface and 15 pCi/g in subsurface soils.
But in some of the Marcellus brines, DEC found levels of radium-226 ranging up to 16,030 pCi/L - more than 3200 times higher than the allowable levels in groundwater and 267 times higher than what’s allowed to be discharged into streams.
On December 30, 2009 Region 2 of the EPA sent 17 pages of formal comments to DEC regarding proposed rules in the SGEIS for drilling in Marcellus and shales. Included in those comments are concerns regarding the management of NORM. EPA noted that NORM concentrations in production brine of Marcellus wells have the potential to far exceed the Maximum Contamination Limits (MCLs) specified in the Safe Drinking Water Act (SDWA). They also question the inconsistency of reporting concentration levels; levels of some radionuclides are reported in pico-Curies per gram (pCi/g) while others are reported in parts per million (ppm). Using ppm as an analytical tool could "significantly underestimate the uranium concentrations," says EPA.