NORM and Fracking.
It is accepted that Naturally Occurring Radioactive Materials are present in returned fracking fluids. Cuadrilla have been obliged to apply to the Environment Agency for radioactive waste permits in addition to "normal" waste disposal permits. Indeed, in our only UK shale fracking experience NORM was registered at up to ninety (90) times the permitted levels applicable to drinking water.
However, the Envronment Agency is only just getting to grips with this. To my knowledge no waste permits were in place at Preese Hall. Another issue here on waste permits is that Cuadrilla in Lancashire for two other wells applied for a waste management permit only. They were, however, obliged in Sussex to apply for a permit including a waste disposal "facility". This is because the Environment Agency NOW consider that the debris, muds and fluids left down a well are after drilling or fracking activities make the underground well a disposal facility.
It remains to be seen how the Environment Agency deal with the EU requirements that such waste and fracking leftovers are obliged to stay within the drilling "target formation". As they have no monitoring facilities to check this, the answer is that fluids may well migrate beyond the shale formations and trespass on adjacent formations.
However, back to NORM. It may become a significant issue, especially if shale gas production starts ,whether disposal of NORM-bearing returned fracking waste fluid can be handled successfully.
But the issue I want to raise here is this. Although the EA require a radioactivity permit for testing, including fracking, they do NOT require one for drilling.
This is despite evidence that drilling cuttings do contain NORM.
In a report to the European Union September 2012, British firm AEA discussed NORM in drilling cuttings. The US experience was not clear-cut.
"Measurement of radioactivity of cuttings from the Marcellus Shale and Barnett Shale found that levels were not significantly elevated above background (New York State 2011 PR p5-
However from another report
"The Paleontological Research Institute (2011 NPR p5) also found that levels of radioactivity in cuttings were not significantly elevated above background, although the US EPA (2012aNPR p4 and p5) reports other data sets from the Marcellus Shale with higher levels of
Naturally-Occurring Radioactive Material (NORM)."
The AEA report conclusion was this-
"Exposure to materials with elevated radiological activity could potentially be of concern with regards to health, but this would only take place in the event of failure of established control
systems. There is insufficient information on the potential for radiological impacts in gasbearing shales in Europe to enable a judgment to be made on the potential significance of
this issue in Europe, although established procedures are in place to address radiological risks.
It is important to ensure proper storage and disposal of cuttings. Established procedures are in place for management of waste from hydrocarbon extraction activity, for example, under
the Mining Waste Directive (see Chapter 3). The introduction of wide scale shale gas extraction would result in a significant increase in the quantities of potentially contaminated
material requiring storage, handling, treatment and disposal. Depending on the nature of shales in Europe, this material may have elevated levels of radioactivity.
So it's the usual story from the US. Scientific reports are inconclusive. None of these tied up with the reports in June this year that trucks of drill cuttings had been turned back from waste disposal facilities in Pennsylvania because alarms were triggered and readings showed radiactivity ten times the permitted level for disposal at the facility.
A Greenpeace article reported that Richard Shaw, radioactive waste team leader at the British Geological Survey considered that although the main problem of enhancement of NORM was by fracking, he admitted the possibility of NORM in cuttings.
He said "“As long as the cuttings and the water are treated appropriately and the resulting filters or sludges are disposed of appropriately in the appropriate facility then I think there should be no issues at all”.
So are the regulations and procedures in the UK there are not?
They are not. According to the EA -
"We have not testing (sic) the wastes arising from drilling for NORM and do not intend to do so. The drilling waste is out of scope of regulation as radioactive waste under the Environmental Permitting Regulations 2010 (EPR2010). The drilling waste can therefore be sent for disposal to a facility permitted to receive it based on the waste’s physical and chemical properties.
The reason why drilling wastes out of scope of regulation is that drilling wells for water, geothermal energy, test boring for mineral exploration, etc do not generally enhance the natural concentration of NORM and are not internationally or generally deemed to be of radiological significance and are not listed as Norm Industrial Activities (NIA’s) requiring regulation.
The implication is clear. The possibility of NORM being present in drill cuttings or drilling muds is officially ignored. It is NOT covered by regulation at all.
Apparently oil "production" is an NIA. But the EA have determined that "production" starts with well stimulation, otherwise the point at which oil flows.
In response to the question whether the EA takes any action to ensure monitoring, the answer is that since there are no regulations all they can say is that wastes are delivered to an appropriate waste site. The EA will do paperwork check to see that a duty of care is met (whatever that means). Again, it is implicitly clear that because of lack of regulation, radioactive materials may be delivered - and are being delivered - to waste disposal sites which have no permit for radioactive materials and have no duty to check for them.
In Lancashire it was finally found that Cuadrilla's drilling wastes had been delivered to a landfill site. In Sussex the EA will not reveal the destination of Cuadrilla's drilling waste because of "recent civil unrest".
So there it is. Another hole in the regulations. Is radioactive material coming to a landfill near you?