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	<title>Comments on: The Disposal of Fracking Waste Includes Radioactive Material</title>
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		<title>By: Wendell Bradley</title>
		<link>https://www.frackcheckwv.net/2018/02/17/the-disposal-of-fracking-waste-includes-radioactive-material/#comment-215310</link>
		<dc:creator>Wendell Bradley</dc:creator>
		<pubDate>Mon, 19 Feb 2018 01:25:42 +0000</pubDate>
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		<description>&lt;strong&gt;Dangers of Fracking Waste, 
Is There Any Safe Way to Dispose of It?&lt;/strong&gt;

Post by Wendell G Bradley, PhD Physics, December 8, 2017

Commercial Landfills in Colorado have been advised that disposal of Oil and Gas Exploration and Production (E&amp;P) waste is not exempt from Colorado Solid Waste Regulations [1], for example, 6 CCR 1007-2. Disposal of fracking waste is a nation-wide problem.

Fracking’s vertical/horizontal drill tailings, flow-back/produced water, scale, and filter socks are all almost certainly radioactive at levels unacceptable for ordinary landfills. Pipe and tank scale exceed acceptable release levels the most due to their continuous build-up of waste [2].

Each oil-well completion destroys from 5 to 10 million gallons of fresh water [Scientific American, July 2015] — permanently removes it from the hydrologic cycle by deep-injection, waste-disposal wells; the lesser value if recycled once. Such injection is necessary because frack waste water is radioactive and otherwise dangerously polluted (benzene, biocides, formaldehyde, etc). Local Operators may or may not use filter socks, thus recycle their frack water. Water recycling is a typical claim, however, to deflect criticism of egregiously wasteful practices in a water-sensitive region.

&lt;strong&gt;The problem is described in detail&lt;/strong&gt;

Operators are likely dumping E&amp;P waste at radiation levels highly in excess of TENORM (technically enhanced, normally occurring radioactive materials) guidelines. This has recently prompted CDPHE’s concern. CDPHE approves radioactive releases at commercial landfills; COGCC at land spreads. Both claim it is the responsibility of ordinary waste recipients to guarantee that TENORM standards are being met. Acceptable release levels for Radium, for example, must be below 3pCi/gm [3]. Official corrective action should be taken (per the federal “AAL” or Analytic Action Level) for releases at levels greater than 210 pCi/gm.

Landfills and land spreads apparently have been relying on the measurements of Operators, who, in turn, justify their releases per a COGCC 2014 study [4]. That study, however, used a discredited measuring/testing protocol [5]. As a result, Operators are typically under measuring by at least factors of 100. Indeed, Table 1 of the Gradient Corporation study (cited above) cites a measurement of Radium in radioactive tank sludge at 1,293 pCi/gm, well above the TENORM-allowed release level of 3 pCi/gm. TENORM standards will require accurate testing for each radioactive dump load since radiation levels differ for each waste category and change over the large distances (2 to 3 mi) that a drilling pad’s spacing unit comprises.

Frack-waste’s radioactivity derives, in part, from the alpha-active NORM elements Uranium (U), Thorium (Th), and Radium (Ra) which cannot be quantitatively measured, only detected, via the conventional Geiger-type or gamma measuring devices Operators have been using to justify their radioactive releases.

A principle radiation danger of frack-waste arises from ingestion of its alpha sources. Although alpha particle radiation cannot even penetrate one’s skin, it can, once inside lungs and other internal organs, cause cancer. Radium is alpha active, water soluble, and bone-seeking. Ra-226 remains a threat for thousands of years–has a half-life of 1600 years. It can become airborne in dust from drill sites, uncovered transport trucks, disposal landfills and field spreads. It can migrate from top soil spills into groundwater.

Assessments conducted by Operators have greatly under measured alpha radiation because they were done on wet frack waste containing high total dissolved solids (TDS) such as salts. It takes a special test for radioactivity in frack-water; the common drinking water test fails.

Ra levels can be underestimated by 99% [Environmental Science &amp; Technology Letters: 2014, DOI:10.1021/ez5000379]  Michael K. Shultz, prof of radiology, U of Iowa, showed EPA’s drinking water test is unsuitable for frack-water’s high TDS (concentration of ions). Indeed, the ‘coprecipitation method’ (of the EPA’s 900 series protocol) accounts for less than 1% of the Ra present. Accordingly, Avner Vengosh, geochemist, Duke U, urges that Ra be measured in frack-water directly with gamma ray spectroscopy. [Chemical and Engineering News, ISSN 0009-2347, copyright @ 2017 American Chemical Society]

The EPA method (900 series protocol) simply doesn’t work in high salt solutions. Even in treated frack-water, Ra levels can measure 200 times higher when proper protocols are used. The 21 day holding period of 900 series protocol is also inadequate.

See also, Analysis of Radium-226 in High Salinity Wastewater from Unconventional Gas Extraction by Inductively Coupled Plasma-Mass Spectrometry, T. Zhang, Dept of Geology and Planetary Science, U of Pittsburgh. [Environmental Science &amp; Technology, 2015, 49(5), pp 2969-2976] Zhang outlines a method that requires only a several-hour holding period, and it matches gamma spectrometry results.

Using EPA’s 900 series measuring protocol allows dumping of large quantities of dangerously radioactive waste into landfills, according to FrackTracker Alliance. A feature in  A Journal of Environmental and Occupational Health Policy [publication 23 (i), 117-35 doi: 10.2190/ns 23.1.h] analyzed fracking’s reserve pit sludge. It found total beta radiation of 1329 pCi/g in Barnett Shale sludge, which exceeded Texas regulatory guide lines by more than 800%.

Accurate radiation measurements of frack-waste require an expensive spectrometry device [6] and at least a 21-day holding period, which an ordinary land fill will not find practical. The cost of independent, third-party safety measurements of radiation should be borne by the Operator.

Source: https://fromthestyx.wordpress.com/2017/12/08/the-dangers-of-fracking-waste/</description>
		<content:encoded><![CDATA[<p><strong>Dangers of Fracking Waste,<br />
Is There Any Safe Way to Dispose of It?</strong></p>
<p>Post by Wendell G Bradley, PhD Physics, December 8, 2017</p>
<p>Commercial Landfills in Colorado have been advised that disposal of Oil and Gas Exploration and Production (E&amp;P) waste is not exempt from Colorado Solid Waste Regulations [1], for example, 6 CCR 1007-2. Disposal of fracking waste is a nation-wide problem.</p>
<p>Fracking’s vertical/horizontal drill tailings, flow-back/produced water, scale, and filter socks are all almost certainly radioactive at levels unacceptable for ordinary landfills. Pipe and tank scale exceed acceptable release levels the most due to their continuous build-up of waste [2].</p>
<p>Each oil-well completion destroys from 5 to 10 million gallons of fresh water [Scientific American, July 2015] — permanently removes it from the hydrologic cycle by deep-injection, waste-disposal wells; the lesser value if recycled once. Such injection is necessary because frack waste water is radioactive and otherwise dangerously polluted (benzene, biocides, formaldehyde, etc). Local Operators may or may not use filter socks, thus recycle their frack water. Water recycling is a typical claim, however, to deflect criticism of egregiously wasteful practices in a water-sensitive region.</p>
<p><strong>The problem is described in detail</strong></p>
<p>Operators are likely dumping E&amp;P waste at radiation levels highly in excess of TENORM (technically enhanced, normally occurring radioactive materials) guidelines. This has recently prompted CDPHE’s concern. CDPHE approves radioactive releases at commercial landfills; COGCC at land spreads. Both claim it is the responsibility of ordinary waste recipients to guarantee that TENORM standards are being met. Acceptable release levels for Radium, for example, must be below 3pCi/gm [3]. Official corrective action should be taken (per the federal “AAL” or Analytic Action Level) for releases at levels greater than 210 pCi/gm.</p>
<p>Landfills and land spreads apparently have been relying on the measurements of Operators, who, in turn, justify their releases per a COGCC 2014 study [4]. That study, however, used a discredited measuring/testing protocol [5]. As a result, Operators are typically under measuring by at least factors of 100. Indeed, Table 1 of the Gradient Corporation study (cited above) cites a measurement of Radium in radioactive tank sludge at 1,293 pCi/gm, well above the TENORM-allowed release level of 3 pCi/gm. TENORM standards will require accurate testing for each radioactive dump load since radiation levels differ for each waste category and change over the large distances (2 to 3 mi) that a drilling pad’s spacing unit comprises.</p>
<p>Frack-waste’s radioactivity derives, in part, from the alpha-active NORM elements Uranium (U), Thorium (Th), and Radium (Ra) which cannot be quantitatively measured, only detected, via the conventional Geiger-type or gamma measuring devices Operators have been using to justify their radioactive releases.</p>
<p>A principle radiation danger of frack-waste arises from ingestion of its alpha sources. Although alpha particle radiation cannot even penetrate one’s skin, it can, once inside lungs and other internal organs, cause cancer. Radium is alpha active, water soluble, and bone-seeking. Ra-226 remains a threat for thousands of years–has a half-life of 1600 years. It can become airborne in dust from drill sites, uncovered transport trucks, disposal landfills and field spreads. It can migrate from top soil spills into groundwater.</p>
<p>Assessments conducted by Operators have greatly under measured alpha radiation because they were done on wet frack waste containing high total dissolved solids (TDS) such as salts. It takes a special test for radioactivity in frack-water; the common drinking water test fails.</p>
<p>Ra levels can be underestimated by 99% [Environmental Science &amp; Technology Letters: 2014, DOI:10.1021/ez5000379]  Michael K. Shultz, prof of radiology, U of Iowa, showed EPA’s drinking water test is unsuitable for frack-water’s high TDS (concentration of ions). Indeed, the ‘coprecipitation method’ (of the EPA’s 900 series protocol) accounts for less than 1% of the Ra present. Accordingly, Avner Vengosh, geochemist, Duke U, urges that Ra be measured in frack-water directly with gamma ray spectroscopy. [Chemical and Engineering News, ISSN 0009-2347, copyright @ 2017 American Chemical Society]</p>
<p>The EPA method (900 series protocol) simply doesn’t work in high salt solutions. Even in treated frack-water, Ra levels can measure 200 times higher when proper protocols are used. The 21 day holding period of 900 series protocol is also inadequate.</p>
<p>See also, Analysis of Radium-226 in High Salinity Wastewater from Unconventional Gas Extraction by Inductively Coupled Plasma-Mass Spectrometry, T. Zhang, Dept of Geology and Planetary Science, U of Pittsburgh. [Environmental Science &amp; Technology, 2015, 49(5), pp 2969-2976] Zhang outlines a method that requires only a several-hour holding period, and it matches gamma spectrometry results.</p>
<p>Using EPA’s 900 series measuring protocol allows dumping of large quantities of dangerously radioactive waste into landfills, according to FrackTracker Alliance. A feature in  A Journal of Environmental and Occupational Health Policy [publication 23 (i), 117-35 doi: 10.2190/ns 23.1.h] analyzed fracking’s reserve pit sludge. It found total beta radiation of 1329 pCi/g in Barnett Shale sludge, which exceeded Texas regulatory guide lines by more than 800%.</p>
<p>Accurate radiation measurements of frack-waste require an expensive spectrometry device [6] and at least a 21-day holding period, which an ordinary land fill will not find practical. The cost of independent, third-party safety measurements of radiation should be borne by the Operator.</p>
<p>Source: <a href="https://fromthestyx.wordpress.com/2017/12/08/the-dangers-of-fracking-waste/" rel="nofollow">https://fromthestyx.wordpress.com/2017/12/08/the-dangers-of-fracking-waste/</a></p>
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