For a printable copy of this document, click here
The Danger of Radioactive Contamination From Fracking in Southern Illinois
●In both conventional oil or gas drilling and in fracking, the oil or gas reservoirs found in shale are mixed with a briney solution known as “formation water.” Southern Illinois shale often includes radioactive elements, so dissolved particles of radium or undissolved particles of uranium or thorium may be in the formation water. During drilling, a mixture of oil, gas, frack water and formation water is pumped to the surface. The water is separated from the oil and gas into tanks or pits, where it is referred to as “produced water.” Thus, produced water may contain concentrated levels of radioactive materials. Produced water is usually re-injected into deep disposal wells or treated for reuse. Some dissolved radium settles out to form sludges that accumulate in tanks and pits, or form mineral scales inside pipes and drilling equipment. (See https://www.epa.gov/radiation/tenorm-oil-and-gas-production-wastes.) In its application, Woolsey Operating Company apparently plans to temporarily store produced water in tanks, then transport it to deep injection wells that are also located in White County (although its application only addresses the initial “flowback” water, not what it intends to do with all produced water).
●Drilling cuttings are another potential radioactive hazard. If uranium, thorium or other radioactive elements are present in the sediment or rocks that contain oil and gas, these materials will be brought to the surface as drilling cuttings, carried by drilling fluid called drilling mud circulating up from the drill bit. This process may pose significant health risks. (See: Technologically Enhanced Naturally Occurring Radioactive Materials in Oil and Gas Production: A Silent Killer; https://www.researchgate.net/publication/282980810_Technologically_Enhanced_Naturally_Occurring_Radioactive_Materials_in_Oil_and_Gas_Production_A_Silent_Killer)
● Gas that escapes during fracking may contain radon, which is not burned off by flaring. Both radon and radium emit alpha particles, which are most dangerous when inhaled or ingested. When inhaled, radon can cause lung cancer, and there is some evidence it may cause other cancers such as leukemia. Consuming radium in drinking water can cause lymphoma, bone cancer, and leukemias. Radium also emits gamma rays, which raise cancer risk from external exposures. Radium is known to bioaccumulate in invertebrates, mollusks, and freshwater fish, where it can substitute for calcium in bones. (Brown, Valerie J., Radionuclides in Fracking Wastewater: Managing a Toxic Blend; Environ Health Perspect., Feb. 2014; DOI:10.1289/ehp.122-A50).
●The volume of wastes from fracking will be far higher than from conventional drilling, since the length of the wells through the host formation can be over a mile long. This means that the risk of hazardous radioactive elements being brought to the surface will also be proportionately greater than in conventional drilling.
● When exterior surfaces of oil-field equipment from conventional oil drilling were sampled for radioactivity by the American Petroleum Institute in 1989, radiation levels greater than five times the median background of all sites were found at approximately 10 percent of the sites. One of the regions particularly noted to have sites with “markedly higher radioactivity” was “southeast Illinois.” (See USGS Fact Sheet, FS-142-99)
● In 1995, the U.S. Geological Survey investigated 43 inactive and active oilfield production sites in Hamilton, Franklin, Gallatin, and White Counties in southern Illinois, in part to survey for radioactivity and determine if naturally occurring radioactive materials (“NORM”), principally radium-226 and radium-228, were present in equipment and soils affected by oilfield solid wastes and produced waters. Five of the sites were revisited in 1996. The study showed that radium in soils affected by tank sludge and produced waters ranged from background levels to a few thousand picocuries per gram total radium (radium-226 and radium-228 combined). These radium concentrations greatly exceeded proposed national safety standards for radium in soils (5 picocuries per gram). Radioactivity levels on oil field equipment and soils also exceeded proposed national standards (25 microroentgens/hour) at 18 of the 43 sites. Laboratory analyses of samples from various sites found moderate levels of lead and other heavy metals in soils contaminated by tank sludge. (James K. Otton, et al., Effects of produced water at some oilfield production sites in Southern Illinois, U.S.G.S. Open File Report 97-448, July 1997)
● The authors of the 1997 study noted that “sites in White County showed elevated radioactivity in oilfield equipment and soils more commonly than sites in the other counties.” Seven of the nine sites investigated in White County were judged to have high radioactivity (>50 microroentgens/hour on equipment, or >30 picocuries/gram radium in sludge, scale, or soils), with one site judged to have moderate radioactivity.
● The dangers posed by bringing radioactive materials to the surface in oil or gas drilling include not only the known risks but the unknown ones as well. This paper cites studies from 1989 and 1995 because so little research has been done on all the potential dangers, let alone what impacts they may have had on workers and communities where drilling has taken place or wastes transported or stored. What we don’t know may hurt us as much as what we do know.
● Simply because a company like Woolsey Operating Company promises to comply with existing regulations, that does not mean that workers or the general public will be adequately protected from the health hazards posed by radioactive elements brought to the surface by fracking operations. The regulations themselves do little to protect us. At the federal level, radioactive oil and gas waste is exempt from nearly all the regulatory processes the general public might expect would govern it. Neither the Atomic Energy Act of 1954 nor the Low-Level Radioactive Waste Policy Act cover NORM. The Nuclear Regulatory Commission has no authority over radioactive oil and gas waste. State laws are a patchwork. (Brown, 2014). Thus, when Woolsey states in its permit application, “If warranted, the appropriate NRC and DOT requirements” for radioactive wastes “shall be followed,” what does that actually mean? No actual regulations are cited in its application.
● The much-touted Illinois regulations require fracking permit applicants to have a “radioactive materials management plan to test for and identify, manage, transport, and dispose of any radioactive materials utilized or generated during the course of” the fracking operations. 62 Ill. Admin. Code § 245.210(b)(7). That sounds good, but the regulations do not specify any safety standards – at all – for worker or public exposure to radioactive hazards. The only thing that the regulations require the applicant to do is test for certain radioactive substances and emissions within 1,500 feet of the well site, and to test drill cuttings, flowback water and the well site during site restoration. The regulations say absolutely nothing about what the company is required to do if hazardous levels of radioactivity are detected, beyond recording the numbers! That is why Woolsey’s three-page Radioactive Management Plan and three pages of its “Site Safety & Health Plan” dealing with radioactive materials are almost entirely devoted to its plans for testing, and say virtually nothing, beyond a few vague statements, about what it will actually do if dangerous levels of radioactivity are detected. In fact, it does not even say what levels of radioactive emissions it will consider dangerous. The regulations don’t require it, so Woolsey is silent. Workers and the public can have no assurance whatsoever that they will be adequately protected from the risk of exposure to unsafe levels of radioactive emissions.
● The regulations do not require the testing of produced water, which presents the greatest danger of radioactive exposure. They do not contain any provision to test for radon in wellhead gas, radium scale in pipe, equipment and crude oil bottom sediment – sometimes used as “road oil.” And of course, there is no enforcement mechanism for radioactive contamination in these categories, either, since there can be no enforcement if there is no mandatory testing and setting of standards.
● Neither the regulations nor the Woolsey application contain any notice requirements for potentially affected residents and workers. There is no provision for workers to wear radiation detection badges or devices. The regulations do not test work areas for levels of radioactivity that would call for OSHA standards of occupational safety. They contain no safety measures for the transport of radioactive waste. They would also apparently allow for the disposal of radioactive contaminated waste in Class II injection wells, which are not designed to safely contain radioactivity.