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

2. 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

3. 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

4. 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.

5. Current KS Prohibits Underground Burial of Low-Level Radioactive Waste
K.S.A 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

6. 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).

7. 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.

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

9. 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.

10. 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