Oil and Gas Drilling Waste Management Challenges NORM and TENORM Issues by John Mitchell, Director Division of Environment Kansas Department of Health and Environment Oil drill rig – Harper County Kansas (Shell Oil drill site) October 2014

Drilling “cuttings” collection Rig has capability of recycling mud. Cuttings are separated from mud via “shakers”. Mud is recirculated and cuttings fall out into dumpsters. Drilling “cuttings” collection

Drill Cuttings and Mud Mixture/Slurry ~ 200,000 gal per well This shows a research and development unit set up at the Harper County Landfill. The landfill’s preference was to apply a cuttings/mud mixture in slurry form across the trash as it was being placed in the fill. Picture shows the pit that was placed for the slurry. Drill Cuttings and Mud Mixture/Slurry

Drilling Waste Issues in Kansas Increased volumes with horizontal drilling Coordination between multiple agencies New Land-spreading laws and regulations Chlorides are primary contaminant of concern NORM/TENORM Considerations - Focus Coordination between agencies (KDHE and KCC predominately; KSU also was involved). Chloride is limit is 900 ppm in waste to be spread. Only two land spreading jobs to date (chloride limit)? Chlorides are primary contaminant of concern – land-spreading limit _________________. NORM/TENORM levels not a problem for Kansas drilling but we needed to allow imports from out of state (CO/OK). So regulations established requirements for analysis of cuttings – database establishment.

Current KS Prohibits Underground Burial of Low-Level Radioactive Waste K.S.A. 48-1620 The board (KDHE) shall not approve any such license which would permit the disposal of low-level radioactive waste (LLRW) below the natural level of the disposal site . . . Statute enacted in 1988. NORM is LLRW per existing statutory definition

Current Drilling Waste Disposal Practices in Kansas Mostly on-site burial in KCC permitted pits Some MSW landfill disposal Some salt cavern disposal Some land-spreading NORM concentration low- up to 1.9 pCi/g Ra-226 up to 1.6 pCi/g Ra-228 State law (from 1988) technically prohibits all NORM disposal except by land-spreading Current disposal practices conflict with state law Law must be changed to address practicalities and true risks to public health Two Radium isotopes of concern in Kansas (Ra 226 and Ra 228). Background concentrations as high as 5.0 pCi/g. Limits will be established in regulation. Practicalities include pipe which has been used for drilling or other production purposes (scale).

KDHE Goals General: Revise Kansas laws and regulations to establish in-state disposal options for wastes containing low concentrations of NORM and TENORM that are protective of public health. Specific: Revise definition of Low Level Radioactive Waste in statute Ensure compatibility with NRC Create new licensing requirement for disposal facilities Create a general license for generators of TENORM Perform general risk assessment for landfill disposal Develop appropriate new regulations We have already worked with NRC to ensure that proposed statutory language is acceptable.

Possible Lined Subtitle D Landfills to Accept NORM and TENORM Solid Waste Public - 11 Private - 7

Other Solid Waste Considerations “Special waste” review and approval process will be used for all NORM/TENORM disposal New landfill operating regulations for NORM/TENORM needed Landfill leachate monitoring of radioisotopes will be required; expanded groundwater monitoring only if found above certain levels in leachate Disposal quantities may be restricted Kansas has an existing Special Waste approval process and this will be used with NORM/TENORM waste that meets the yet to be established Radium isotope limits. Leachate monitoring will be required at least on an annual frequency.

Interest of Eligible Landfills Uncertain ?? New added costs of operation Market potential Long-term liability Reporting, monitoring, public sensitivity Small license fee All handled by Bureau of Waste Management to reduce regulatory burden