radioactivity of shale drill cuttings

7/28/2019 Radioactivity of Shale Drill Cuttings

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Radioactive WasteManagement Associates

MemoTo: Interested Parties

From: Marvin Resnikoff

Date: 7/4/2013

Re: Radioactivity in Rock Cuttings

Allied Landfill

In August 2012, rail shipments from a Cabot Oil drill site in Susquehanna County, PA, triggered aradiation detection alarm at the Allied landfill in Niagara County, NY and were held for four monthswhile samples were taken. The samples were sent to a TestAmerica lab in Earth City, MO. Forradium-226, the concentrations ranged between 1.6 and 206 pCi/g. After demonstrating that theactivity concentrations of the rock cuttings were below DOT regulations1 49CFR173.436, the rockcuttings were eventually not accepted at Allied and cleared for return to Cabot Oil.

DOT Regulations

Under Federal DOT rules, transported material that exceeds specific activity concentrations and total

activity, in terms of total Curies of radioactivity, is classed as a radioactive material. Correspondencebetween DEC and the shipper make reference to the activity concentrations that are indeed below2.7x10-10 Ci/g Ra-226 and fail to make reference to the total activity. The specific limit for total Radium-226 is 2.7x10-7 Curies2. Below this total activity, the material is not classed as radioactive by DOT;above this amount, specific Federal regulations apply regarding design, packaging and labeling oftransportation vehicles. For placarding, the NRC has even stricter limits for total activity, 1 x 10-7 Curies(10CFR20, App. C). DEC did correctly question whether shipments to the Allied landfill should be listedas radioactive under DOT regulations. For 20 ton truckloads, and definitely for a rail car load, the totalCi content exceeds 2.7 x 10-7 Ci.

1 Letter from URS to J Smelko, Cabot Oil, December 21, 2012. This note and all correspondencerefers to 40CFR173.436, not 49CFR173.436. 40CFR 173.436 refers to pesticides under EPAregulations whereas title 40 are DOT regulations.2 49 CFR 173.436 - Exempt Material Activity Concentrations and Exempt Consignment Activity Limitsfor Radionuclides." U.S. Government Printing Office. U.S. Government Printing Office. Web. 21 May2013. .

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If a shipment is class 7 or radioactive under DOT regulations, specific conditions apply. Under 49 CFR173.410 and 173.411, any package used for the transportation of radioactive materials must be easilyhandled and properly secured with a structurally sound lifting attachment, will have an external surfacefree from protruding features that can be easily decontaminated, all valves through which the packagecontents could escape will be protected against unauthorized operation and the behavior of thepackaging and contents under irradiation will be taken into account. Additionally, the materials thatqualify as a Low Specific Activity II waste, must be properly packaged in Industrial Packaging Type 2(IP-2) or Industrial Packaging Type 3 (IP-3) enclosures.

In addition, vehicles transporting hazardous substances, such as rock cuttings or brine, must hold aninsurance policy with a minimum level of financial responsibility of $5,000,000. The state of Ohiorequires each transporter of brine to hold a liability insurance policy that would cover both bodily injuryand property damage caused by processing associated with brine for $600,000. We have not checkedNew York State DOT regulations, but they must be consistent with federal regulations since these areinterstate shipments. Most insurance policies for private cars have liability coverage greater than $1million.

Finally, federal DOT regulations require that hazardous and radioactive shipments be properlyplacarded. Specifically, federal DOT regulations require this notice:

RADIOACTIVELSA or RADIOACTIVESCO. Instead, trucks we have seen on Pennsylvaniahighways are simply labeled brine.

Radioactive Concentrations of Rock Cuttings

In a report we wrote in a DEC case concerning expansion of the Chemung County solid waste landfillto accept rock cuttings from Pennsylvania3, we cited a USGS study4 and gamma logs from drillingcompanies as proof that Ra-226 concentrations ranged up to 30 pCi/g. We were heavily criticized bythe gas drillers, who provided proof that rock cuttings were essentially background. These recentmeasurements by DEC, with Ra-226 concentrations up to 206 pCi/g, along with high radiation readingsat the MAX landfill in PA, show that our upper range assumptions were apparently too low. These Ra-226 concentrations by DEC at the Allied landfill have major implications for landfill disposal in New YorkState, Pennsylvania and Ohio, and major implications for radon gas in pipelines to metropolitan areas

such as New York City and Philadelphia, where radon gas can enter homes through kitchen stoves.We intend to discuss the implications in more detail in a subsequent report.

3 Chemung County Landfill permit modification, Application No. 8-0728-00004/00013, petition byRFPLC to intervene, April 2010.4 Leventhal J, Crock J, and Malcolm M; United States Department of the Interior, Geological Survey.Geochemistry of trace elements and uranium in Devonian shales of the Appalachian Basin. 1981;(Open File Report 81-778).

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radioactivity of shale drill cuttings

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