Shale Gas Wastes: Ohio Public Policy & Potential Impacts to

Water Supplies

Julie Weatherington-Rice, PhD, CPG, CPSS

Bennett & Williams Environmental Consultants Inc.

An Ohio Fracture Flow Working Group

Presentation

May 2, 2013

Adj. Asst. Prof, Ohio State U. Food, Ag & Bio Eng.

2013 Focusing on Shale Gas 2013 Focusing on Shale Gas WastesWastes

• Ground Shale Rock:Ground Shale Rock: hydrocarbons, heavy & hydrocarbons, heavy & radioactive metals, Ohio–NORM, radioactive metals, Ohio–NORM, US EPA-US EPA-TENORMTENORM

• Drilling Muds: Drilling Muds: who knows what, who knows what, TENORMTENORM

• Fracking FluidsFracking Fluids: : water, sand, who knows water, sand, who knows what, if recycled, are they what, if recycled, are they TENORM?TENORM?

• Brine:Brine: salts, hydrocarbons, heavy & salts, hydrocarbons, heavy & radioactive metals, Ohio-NORM, radioactive metals, Ohio-NORM, US EPA-US EPA-TENORMTENORM

• Drilling Site Wastes & Accidental Drilling Site Wastes & Accidental Releases:Releases: who knows what is being releasedwho knows what is being released

• Where are they coming from?Where are they coming from?

• Where are they going?Where are they going?

• Ohio has paid for State & Local Ohio has paid for State & Local governments by taxing governments by taxing (tipping fees, etc.) (tipping fees, etc.) out out of state waste streams of state waste streams (solid, C&DD, industrial, (solid, C&DD, industrial, medical, O&G, etc.)medical, O&G, etc.) for last 20+ yearsfor last 20+ years

• Shale Gas drilling has created a big, new Shale Gas drilling has created a big, new waste stream not addressed by surrounding waste stream not addressed by surrounding states states - seen as a new & easily captured revenue - seen as a new & easily captured revenue source by Ohio’s Administrationsource by Ohio’s Administration

• Ohio DOES NOT have magic GEOLOGY Ohio DOES NOT have magic GEOLOGY – that can swallow all wastes without that can swallow all wastes without

repercussions repercussions

Why the Current Why the Current Concern?Concern?

Why the Current Concern Why the Current Concern Cont?Cont?• Blacks shales are early sources of Uranium ore for Blacks shales are early sources of Uranium ore for

the “Atomic Age” the “Atomic Age” (Chattanooga Shale, TN; USGS, 1961)(Chattanooga Shale, TN; USGS, 1961)

• Black shales like coal are full of heavy and Black shales like coal are full of heavy and radioactive metals: radioactive metals: 232232Th to Th to 228228Ra & Ra & 238238U to U to 226226Ra are Ra are most common seriesmost common series

• 228228Ra, Ra, 238238U & U & 226226Ra water soluble, also in brinesRa water soluble, also in brines

• US EPA limit on Uranium mill tailings, 5 pCi/g US EPA limit on Uranium mill tailings, 5 pCi/g because of the Radium: because of the Radium: > LLRW Landfill, Utah or > LLRW Landfill, Utah or Washington State accept NORMWashington State accept NORM

• US EPA Drinking Water MCL 5 pCi/L for RadiumUS 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 Why the Current Concern Cont?Cont?• Very limited chem data Very limited chem data (gamma)(gamma) for Utica shale, for Utica shale, TENORMTENORM

& brines: & brines: 100’s to 1,000’s X 5 pCi/g or L100’s to 1,000’s X 5 pCi/g or L

• PA DEP Marcellus Shale U content: PA DEP Marcellus Shale U content: 10-100 ppm10-100 ppm

• Uranium-238 content: Uranium-238 content: ~3.4 to 34 pCi/g~3.4 to 34 pCi/g

• Radium-226 content: Radium-226 content: ~ 3.4 to 34 pCi/g~ 3.4 to 34 pCi/g

• Frac Water Ra-226: Frac Water Ra-226: 300 to 9,000 pCi/L300 to 9,000 pCi/L

• PA Marcellus brine chemistry up to 3,609 x MCLs for PA Marcellus brine chemistry up to 3,609 x MCLs for radioactivity: radioactivity: 5 pCi/L US EPA5 pCi/L US EPA– USGS reports median levels Ra >3x PA brines from conventional USGS reports median levels Ra >3x PA brines from conventional

wellswells

Gamma Spec Data

Water Soluble

Bones

Why the Current Concern Why the Current Concern Cont?Cont?

• NY brine up to NY brine up to 15,000 pCi/L 15,000 pCi/L 226226RaRa

• Hard scale in used drilling Hard scale in used drilling pipes up topipes up to 6,000 pCi/g 6,000 pCi/g 226226Ra and Ra and up to 2,000 pCi/g up to 2,000 pCi/g 228228RaRa

• Ohio still contaminated Ohio still contaminated from the Manhattan Project from the Manhattan Project – we know better now we know better now

Radioactivity = TOC = Radioactivity = TOC = GasGas

• Gamma Ray Gamma Ray signature shows signature shows highest levels of highest levels of radioactivity in radioactivity in the shalethe shale

• Horizontal laterals Horizontal laterals installed in installed in hottest zoneshottest zones

• Shale cuttings are Shale cuttings are from hottest areasfrom hottest areas

5 pCi/L MCL: Why the Health 5 pCi/L MCL: Why the Health Risk?Risk?

Because water-soluble Radium replaces Calcium in your bones if you drink it, Pb-210 also a bone

seeker

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40?

Shale Gas Wastes: A Shale Gas Wastes: A Growth Industry for OhioGrowth Industry for Ohio

• Wastes coming into Ohio by road, rails & soon by Wastes coming into Ohio by road, rails & soon by river barge, port Washington Co. in placeriver barge, port Washington Co. in place

• Over 52% 2012 injections in Class II wells came Over 52% 2012 injections in Class II wells came from out of state, mostly PA & WVfrom out of state, mostly PA & WV

• Dedicated out-of-state Class II wells being Dedicated out-of-state Class II wells being installed in SE Ohio installed in SE Ohio (new one Athens Co.)(new one Athens Co.)

• No Public Hearings being held for anyoneNo Public Hearings being held for anyone

• With NY still to be decided & barge ports for With NY still to be decided & barge ports for Ohio River/Gulf wastes coming on line Ohio River/Gulf wastes coming on line – may be up to 80% out of state wastes in a few yearsmay be up to 80% out of state wastes in a few years

• Ground Shale Rock with drilling muds to Ground Shale Rock with drilling muds to Solid Waste and C&DD Landfills; no Solid Waste and C&DD Landfills; no records of how much or where, just listed records of how much or where, just listed as “solid wastes”; used as daily cover, as “solid wastes”; used as daily cover, not buriednot buried

• All Fracking Fluids & Brines to be injected All Fracking Fluids & Brines to be injected in Class II wells except when spread on in Class II wells except when spread on roads (brines), “solidified” and put in roads (brines), “solidified” and put in landfills or other management processes landfills or other management processes yet to be determinedyet to be determined

• ODNR Div. Oil & Gas Resources calls the ODNR Div. Oil & Gas Resources calls the shots; OEPA and ODH are secondshots; OEPA and ODH are second

Shale Gas Wastes: A Shale Gas Wastes: A Growth Industry for Ohio Growth Industry for Ohio

cont.cont.

New ODNR OEPA ODH New ODNR OEPA ODH Regulation ChartRegulation Chart

• Waste Streams Generated During the Waste Streams Generated During the Exploration and Production for Oil Exploration and Production for Oil and Natural Gasand Natural Gas

• Summary of Potential Regulatory Summary of Potential Regulatory Oversight, January 2013Oversight, January 2013

• www.epa.state.oh.us/portals/34/www.epa.state.oh.us/portals/34/document/NewsPDFs/Oil-Gas Waste Matrix document/NewsPDFs/Oil-Gas Waste Matrix Jan20132.pdfJan20132.pdf

• Check it outCheck it out

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

Class II Injection WellsClass II Injection Wells• Class II Injection Wells Class II Injection Wells

RevisionsRevisions

(above Pre-Cambrian (above Pre-Cambrian basement rock now)basement rock now)

Seismic rules added by Seismic rules added by emergency in 2012 to emergency in 2012 to lift moratorium, 30+ lift moratorium, 30+ waiting applications waiting applications being processed & being processed & approved approved

• Check new web site often Check new web site often www.oilandgas.ohiodnr.govwww.oilandgas.ohiodnr.gov

Shallow to Mt Simon

What are Class II Injection What are Class II Injection Wells?Wells?• Class I – Hazardous Class I – Hazardous

WasteWaste

• Class II – Oil & Gas Class II – Oil & Gas FluidsFluids

• Class III – Solution Class III – Solution Mining of MineralsMining of Minerals

• Class IV – Class IV – now bannednow banned

• Class V – Stormwater, Class V – Stormwater, etc.etc.

• Class IV – CO2 Class IV – CO2 SequestrationSequestration

Why Do We Have Them in the Why Do We Have Them in the First Place?First Place?

• Originally used to Originally used to rehabilitate old rehabilitate old O&G fieldsO&G fields

• Converted Converted production wells in production wells in field to be field to be rehabbedrehabbed

• Brine & other fluids Brine & other fluids injected back into injected back into field to force out field to force out remaining productremaining product– Called “Flooding”Called “Flooding”

How Do How Do They Fail?They Fail?

• Limited Site Visits by Limited Site Visits by OperatorsOperators– can be operated 24-7-365can be operated 24-7-365

• Surface & Near Surface SpillsSurface & Near Surface Spills– from valves, lines & tanksfrom valves, lines & tanks

• Compromised Spill Protection Compromised Spill Protection SystemsSystems

• Structural Failure Over TimeStructural Failure Over Time– Casings and CementCasings and Cement

• Earthquakes, increases w/ Earthquakes, increases w/ increase in pressure increase in pressure – (National Resources Council rept., (National Resources Council rept.,

www.nap.edu/catalog.php?record_id=13355) www.nap.edu/catalog.php?record_id=13355)

Do We Even Need Them?Do We Even Need Them?

• Important for SS & LS O&G well Important for SS & LS O&G well field rehabilitation field rehabilitation – but not for shale gas productionbut not for shale gas production

• All other uses All other uses – long term, probably notlong term, probably not

• Planning now for the short term Planning now for the short term & intermediate futures & intermediate futures

Legal disposal for shale rock cuttings, drilling muds and associated wastes

HB 59 required downblending if Ra levels above MCLs for TENORM only, language removed but Admin trying to put back in Senate versionNo requirement that chemical binding of radioactive materials to dilution materials must occur

Landfilling the WastesLandfilling the Wastes

But are they LLRW But are they LLRW Landfills?Landfills?• No solid waste and No solid waste and

C&DD waste C&DD waste landfills in Ohio landfills in Ohio meet our siting & meet our siting & design criteria for design criteria for LLRW disposalLLRW disposal

• OSU Extension OSU Extension Research “Low-Research “Low-Level Radioactive Level Radioactive Waste Fact Sheet Waste Fact Sheet Series” (RER-00) Series” (RER-00) explains why explains why

Cement vaults above ground, wastes drummed,

overpacked and sealed

Ohioline.osu.edu/rer-fact/

Our Studies Show Real-Time Measurements

Unreliable• Radium a weak

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

Other Solutions for Brine Other Solutions for Brine Disposal Sure to Reach the Disposal Sure to Reach the

WaterWater

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

Recycling of Fracking Recycling of Fracking FluidsFluids• Chesapeake in Carroll County, OhioChesapeake in Carroll County, Ohio• Range Resources in PARange Resources in PA• Consol/Epiphany/PMC Biotech solar Consol/Epiphany/PMC Biotech solar

powered recycling pilot plant started powered recycling pilot plant started in July 2012 in PAin July 2012 in PA

• Number of others as wellNumber of others as well

Why? Why? Because they need the water for the Because they need the water for the next well & savings on reclaimed chemicalsnext well & savings on reclaimed chemicals

Potential Problems from Potential Problems from RecyclingRecycling

• Recycled fracking fluids need to be filteredRecycled fracking fluids need to be filtered– to remove sand, rock cuttings, etc. before being to remove sand, rock cuttings, etc. before being

reusedreused

• Filtered materials go to landfillsFiltered materials go to landfills

• Reusing the fluid increases the levels of Reusing the fluid increases the levels of Radium each time through, not removedRadium each time through, not removed

• Eventually TDS etc. so high that fluid must Eventually TDS etc. so high that fluid must be disposed of in Class II wells anywaybe disposed of in Class II wells anyway

• Ohio not collecting information on Ohio not collecting information on Recyclers Recyclers – who/where they are, how they collect fluids, who/where they are, how they collect fluids,

how dispose of wasteshow dispose of wastes

Repurposing of O&G Repurposing of O&G BrineBrine• Almost everything in O&G brine has an Almost everything in O&G brine has an

industrial application & a current marketindustrial application & a current market• Already “mine” salts in Ohio for industrial Already “mine” salts in Ohio for industrial

applicationsapplications• DOE/GE working on process to remove DOE/GE working on process to remove

Radium-228 and 226 from brineRadium-228 and 226 from brine• Technology already exists to break O&G Technology already exists to break O&G

brine down, working on economicsbrine down, working on economics• Why dispose of resources we need & would Why dispose of resources we need & would

have to make/extract in other ways for have to make/extract in other ways for other costs?other costs?

• Ohio could still extract “tax” for out-of-Ohio could still extract “tax” for out-of-state brine if reprocessed here, real jobs state brine if reprocessed here, real jobs for Ohiofor Ohio

Contacts for this presentation Contacts for this presentation & Ohio Journal of Science & Ohio Journal of Science PapersPapersOFFWG,OFFWG, Dr. Julie Weatherington-Rice, Dr. Julie Weatherington-Rice,

B&W, OSU FABE,B&W, OSU FABE, weatherington- weatherington-ri.1@osu.edu ri.1@osu.edu

OFFWG, OFFWG, Dr. Ann Christy, OSU FABE,Dr. Ann Christy, OSU FABE, christy.14@osu.educhristy.14@osu.edu

Bennett & WilliamsBennett & Williams, Linda Aller RS,, Linda Aller RS, Laller@bennettandwilliams.comLaller@bennettandwilliams.com

Ohio Journal of Science Web Link at Ohio Journal of Science Web Link at OSU, OSU, https://kb.osu.edu/dspace/handle/1811/https://kb.osu.edu/dspace/handle/1811/686686

Ohio EPAOhio EPA Division of Drinking and Ground Division of Drinking and Ground Waters Source Water Assessment and Waters Source Water Assessment and Protection Program,Protection Program, www.epa.ohio.gov/ddagw/swap_ssa.aspwww.epa.ohio.gov/ddagw/swap_ssa.aspxx

Keeping Ohio’s Water CleanOhio Fracture Flow Working

Group

Even Without Disposal Even Without Disposal Issues, Does it Make Issues, Does it Make Current Economic Sense to Current Economic Sense to Drill?Drill?

• Drilling Costs Drilling Costs >$42 Billion/yr >$42 Billion/yr to maintain to maintain productionproduction

• Dry Gas Sales Dry Gas Sales ~$33 Billion/yr~$33 Billion/yr

• Some additional Some additional value from wet value from wet gasesgases

JD Hughes, 2013, Nature vol. 494

How long to Protect from human interaction if use Michigan’s 50 pCi/g limit • 50 pCi/g Radium-226 (1,609 yrs/1/2 life) to

5 pCi/g is 3+ half lives, ~5,000 yrs, beginning of Egypt's pyramids

• 50 pCi/g Uranium-238 (4.468 Billion yr/1/2 life, from almost the birth of the earth until now 1 ½ life) to 5 pCi/g, so 3+ half-lives, back to the beginning of the Universe

• 50 pCi/g Thorium-232 (14.05 Billion yr/1/2 life, longer than the age of the Universe until now 1 ½ life) to 5 pCi/g, ~45 Billion years, more than the diameter of the visible universe