Three Things to Know About University of Iowa’s Study On Marcellus Solid Waste
This week, researchers from the University of Iowa released a study that analyzed just three solid waste samples from one Marcellus Shale well (yes, you read that correctly). Despite this extremely limited sampling, the researchers claim their research found new types of radiation that Pennsylvania and West Virginia regulatory agencies have not previously included in evaluations of Marcellus solid waste, and that “that further testing is needed to understand what is in solid waste from the country’s proliferating horizontal wells and whether it might pose any environmental risks.”
Aside from the obvious fact that further testing should have been done prior to releasing any findings, here are three things to keep in mind when reading this study.
Fact #1: Three samples from one well is not enough to draw any kind of conclusion.
From the report:
“Three solid samples were obtained from a single well in northern PA. The first sample was taken from the vertical, air-drilled section (1380 m) extracted in mid-November 2015, and the two other samples were extracted from the horizontal section (2060 and 3430 m) in mid-December 2015.” (emphasis added)
Three samples. One well.
There is absolutely no way to make comparisons, analyze averages or draw any kind of conclusion by simply looking at minimal samples from a single well. This is literally a study of the drill cuttings of one well in Northeastern Pennsylvania and cannot possibly be used to make a general statement of wells across the Northern Tier or in other parts of the state.
Fact #2: Pennsylvania has strict regulations on anything radioactive being transported to landfills.
Let’s look past the sample size momentarily, because even if the researchers had sampled 1,000 wells, the fact remains that Pennsylvania has very strict regulations on transporting and disposing anything remotely radioactive into landfills.
Chapter 288 of Pennsylvania’s Residual Waste Landfills regulation regulates all Marcellus waste and includes sections 301 and 302 of the Radiation Protection Act, which specifically regulates disposal of drill cuttings into landfills. In addition to monitoring, these regulations even dictate specific areas of the landfill that can be used for materials releasing radiation:
“288.133. Map and grid requirements. (14) For noncaptive residual waste landfills, a designated area for vehicles for use in the event of the detection of waste containing radioactive material. The designated area shall, by location or shielding, protect the environment, facility staff and public from radiation originating in the vehicle. The Department’s ‘‘Guidance Document on Radioactivity Monitoring at Solid Waste Processing and Disposal Facilities,’’ Document Number 250-3100-001, describes various factors to consider in determining an appropriate designated area.”
Landfill company Waste Management explains this was an important part of Pennsylvania’s regulatory framework even before the first Marcellus well was drilled:
“In 2000, the state Department of Environmental Protection (DEP) adopted new regulations requiring landfills to monitor all incoming wastes for radioactivity, even residential trash from the curb. Pennsylvania was first in the nation to introduce these regulations as a precautionary principle, taking advantage of improvements in technology to detect sources of radiation.” (emphasis added)
Here’s an idea of how sensitive the radioactive waste monitoring equipment used by Waste Management’s Alliance Landfill is:
“All vehicles that carry waste to Alliance’s working area pass across the landfill’s scales where they are weighed and subjected to our radiation monitoring system. This system tells us if a load of waste contains any radioactive material. It provides an extra measure of safety for our employees and the environment.
What our monitors routinely detect are items discarded by people receiving radiological medical treatment, including adult diapers, tissues, papers and paper cups. We’ve also found kitty litter used by pets receiving this type of veterinary treatment. Alliance, in accord with state guidelines, is allowed to accept these wastes. Our monitors are so sensitive they have detected visitors who’ve recently received these types of medical treatments, including a site tour visitor who had recently undergone a CT Scan.
On occasion other types of radiation have been detected, including a radioactive medical needle that dated to the 1950s and a World War II-era aircraft gauge that was painted with glow-in-the-dark paint that was radioactive (something that wasn’t uncommon years ago). When items like these are detected, they are either returned to their place or origin or placed in special packaging and shipped to an appropriate disposal site.” (emphasis added)
Trucks carrying Marcellus drill cuttings must undergo this same monitoring. Additionally, waste produced from oil and gas development is also regulated under Chapter 78 of Pennsylvania’s oil and gas regulations, which require radioactivity logs to be submitted to the Pennsylvania Department of Environmental Protection (PADEP) within 90 days of completing a well.
PADEP monitors those logs as well as reports submitted from landfills for instances of high radiation. But to date this hasn’t been an issue for Marcellus waste. In fact, according to PADEP:
“DEP’s data indicates that less than half a percent of all drill cuttings produced by the Marcellus Shale industry in 2012 that were disposed of in landfills triggered radiation monitors. The cuttings did not contain levels of radioactivity that would be harmful to the public, and they were safely disposed of in the landfills.”
Fact #3: Pennsylvania and West Virginia conducted separate studies in 2015 finding little concern for leaks or harm to workers from Marcellus waste.
The University of Iowa researchers explained in their study,
“In 2015, PA and WV (West Virginia) released studies on the NORM content of Marcellus Shale cuttings, indicating that radioactivity levels in cuttings from horizontal portions of an unconventional well were higher than those from vertical portions. The studies also concluded that drill cuttings pose minimal risk to the general public.” (emphasis added)
Despite this acknowledgement, the researchers dismissed these studies, stating,
“Although this conclusion may be the case, these reports focused on only several long-lived radionuclides…”
In other words, they are saying the studies didn’t look at enough possibilities since they addressed the most common sources of radiation found in Marcellus cuttings across the state. The reality is that both studies were in-depth analyses of potential radiation sources resulting from Marcellus development in each state — and neither study found anything of concern.
“There is little potential for radiation exposure to workers and the public from landfills receiving waste from the O&G industry. However, filter cake from facilities treating O&G wastes are a potential radiological environmental impact if spilled, and there is also a potential long-term disposal issue. TENORM disposal protocols should be reviewed to ensure the safety of long-term disposal of waste containing TENORM.” (emphasis added)
“…The researchers found little concern with regards to the leachate from drill cuttings that were placed in approved and permitted landfills, once that leachate was processed through a correctly operated treatment facility.” (emphasis added)
Even if this study had arrived at its conclusion after evaluating a multitude of samples rather than just three cuttings from one well, that wouldn’t change the fact that Pennsylvania has strict regulations and monitoring protocols in place on anything radioactive being transported to landfills. Additionally, Pennsylvania and West Virginia Environmental regulators have conducted studies that have found Marcellus drill cuttings pose minimal risk to the general public. All told, it is clear that landfills accepting Marcellus waste — or any waste that could potentially be radioactive — are serious about protecting workers and the environment.