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| 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.
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