Under The Rug: A Story of Radium in Fuel
Introduction
What is under the rug? According to the idiom, that’s where the dirt is swept. The figurative meaning is to keep something embarrassing, unappealing, or wrong from public view and scrutiny. This report will demonstrate that this is occurring on a massive scale within the oil and gas industry, with the industry’s products, and with its disposal methods including injection wells. The dirt, in this case, is radioactive.
Radioactive waste is the byproduct of wells that have been drilled through deep layers of rock, which contain heavy metals and radioactive materials. This radioactive waste is then sold as a variety of products and dispersed around the country. Products include packaged salt for ice melt, brine treatment for frozen roads, pool salt, irrigation for vegetation, and construction fill material. Radioactive sludge also builds up in pipes, which are eventually taken to landfills, turned into playgrounds, and even made into school bleachers.
The radioactive waste that cannot be converted to products is pumped into the ground via injection wells. The oil and gas industry have their own classification of injection well (Class 2), which does not permit radioactive waste. Frequently, however, the extraction companies are allowed to monitor themselves for regulatory compliance. Legal loopholes and crafty accounting help violators avoid being shut down and protect regulators from charges of negligence and misconduct. This report will highlight the role that regulators have played in preventing citizens from taking legal action or becoming informed. Additionally, it will look at how long the industry has known about the problem of radioactive materials in its processes.
Background
In 1904, a scientist from the University of Toronto encountered a highly radioactive gas emanating from samples of oil that were heated and had air bubbled through them (Burton, 1904). In his paper, entitled “A Radioactive Gas from Crude Petroleum,” scientist E. F. Burton demonstrated that the emanating gas had the same properties as emanations from Radium, which had recently been discovered by Marie Curie. In the same year, Professor Von F. Himstedt published a study in the German language “Physikalische Zeitschrift,” which identifies radioactive emanations that are absorbed by water and petroleum (Himstedt, F., 1904). In a letter to the editor at Nature magazine, published in 1904, physics Professor J.C. McLennan related his findings of natural gas wells examined in Niagara Falls and found a short-lived radioactive gas emanating from them (McLennan, 1904). To be clear, the gas identified in those papers had a short half-life of only a few days, and all three papers recognized that the gas was a part of what was called radium emanation. That gas now has the universally accepted name of radon.
The discovery of radium, by Marie Curie, was the culmination of a search for an unknown element that was giving off more radiation and heat than the Uranium that it was separated from (Curie, 1904). Radium-226 and Radium-228, which have half-lives of 1600 years and 5.75 years, respectively, are the “daughter” isotopes of Uranium-238 and Thorium-232. The half-life of Uranium-238 is approximately 4.5 billion years and the half-life of Thorium-232 is 14 billion years. The theory of radioactive decay and half-lives means that in 4.5 billion years half of a quantity of Uranium-238 will still be radioactive and decaying into radium. In 9 billion years a quarter of the same quantity of Uranium-238 will still be radioactive and decaying into radium. Uranium, thorium, and their “daughter” isotopes, such as radium, polonium, and bismuth, eventually decay into a non-radioactive form of lead, namely Lead-206 and Lead-208 (US EPA, 2015(a)).
Moving through this timeline of radioactive discovery it is important to pause, take a social detour, and examine some of the consequences of radioactivity. Radium necrosis is a deterioration of bones resulting from radium exposure (“Radium Necrosis”, 2011). Radium necrosis frequently manifests as radium jaw, which can involve the jaw falling off a person’s face from decay (“Radium Jaw”, 2010). Examples of such an extreme outcome, can be found in the cases of the Radium Girls and Eben Byers.
The “Radium Girls” worked in watch factories that used radium to paint glowing watch faces. From the late 1910’s until the late 1930’s, many women were injured and died from licking radium-soaked brush tips, to improve workplace efficiency, and applying the radium as make-up (Vaughan, n.d.). The women were not made aware of the dangers, even though plant managers and company owners had knowledge of the risks. (Gunderman & Gonda, 2015).
The story of Eben Byers is a similar cautionary tale. Eben was a wealthy, highly educated socialite who started consuming a radium water medicine called Radithor, which was prescribed by his doctor (Tapalaga, 2021). Four years later, his jaw fell off. In the following year, Eben died when the radium had caused his internal organs to decay. Radium is similar in its structure to calcium; therefore, it easily attaches to bones and is known as a “bone-seeker” (National Academies of Sciences, 1988).
Returning to the timeline of discovery, the next stop is in 1921, the year the United States Geological Survey (USGS) came out with a report titled “Helium-Bearing Natural Gas” (Sherburne Rogers, 1921). The report discusses, at length, the correlation between radioactive elements, helium, and natural gas. For example, on page 64 the report states that, “the natural gas of Petrolia and Canada and the oil from many other localities are radioactive, apparently owing to the great solubility of radium and thorium emanation in petroleum.” This demonstrates the awareness within the scientific community, as well as the Department of the Interior, of radioactive isotopes in petroleum and natural gas.
Thirty-nine years later, another Department of Interior/USGS report, “Oil Yield and Uranium Content of Black Shales,” discusses how uranium is related to the organic matter in shale rock (Swanson, 1960). The paper presents estimates, based on over 500 samples of black shale rock, of how much oil and uranium are present in different formations in the United States, as well as other locations, such as Sweden, Brazil, and South Africa. Relevant findings include black shales having “as much as one hundred times more uranium than other common sedimentary rocks,” large quantities of oil and uranium having been recovered from black shales in Sweden, and above average uranium content in black shale rock samples from various locations. The paper discussed the costs and difficulty of extracting both oil and uranium from thin layers of shale. Concluding, that in the future black shale rock can be an economically viable source of both products.
By the mid 1960’s, black shale formations in Ohio were being viably accessed using hydraulic fracturing (NES, 2019). Hydraulic fracturing uses water, sand, and chemicals to fracture rock layers. This process increases the extraction of oil and gas from wells that have reduced production or from layers of rock which normally are not productive (USGS, n.d.). Further access to black shale rock was enhanced with horizontal drilling in the 1980’s. This allowed greater access to a larger area of a thin, horizontal shale rock layer than just drilling vertically down into it. In other words, one horizontal well can access more shale rock and extract more materials than multiple vertical wells.
In the interim between the use of hydraulic fracturing and horizontal drilling to access shale rock, the Solid Waste Disposal Act (SWDA), as well as several accompanying amendments were passed by the U.S. Congress (US EPA, n.d.(a)). The SWDA was signed into law because of an increase in American industrialization, and the waste that came with it. By 1976, the amendment known as the Resource Conservation and Recovery Act (RCRA) was passed to address the inability of the SWDA to control industrial pollution (US Congress, 1976)
Subtitle C, of RCRA, required the U.S. Environmental Protection Agency (EPA) to manage wastes from their creation to their disposal, aka “cradle to grave” (Luther, 2013). By 1980, the largest industrial wastes were still not regulated as hazardous and a new set of rules, called the Bentsen and Bevill Amendments, further exempted wastes from oil, gas, and coal operations. The reason, ostensibly, was because the wastes were so large in volume that management would be too cumbersome. Under these new amendments, the EPA was required to research the risks of managing the wastes and report back to the U.S. Congress by 1982 (Luther, 2013). After missing the 1982 deadline, getting sued in 1985, and receiving an extension in 1987, the EPA decided in 1988 that all the wastes exempted in the Bentsen and Bevill Amendments should remain exempted. These exemptions were further extended and clarified in 1993, 2002, and 2008 (US EPA, n.d.(a)).
While the EPA was researching the risks of these industrial wastes, several government and industrial reports had already come to definitive conclusions. Among them was a 1978 report for the U.S. Department of Energy, from the University of Denver, which confirmed the link between shale/peat deposits and uranium content (Schmidt-Collerus, 1978). In 1982 the American Petroleum Institute commissioned an internal report on “radionuclides.” Page 2 of that report stated, “Almost all materials of interest and use to the petroleum industry contain measurable quantities of radionuclides” (API, 1982).
In 1988, the Louisiana Department of Environmental Quality (LDEQ) published a report that was republished as a memorandum by the Occupational Safety and Health Administration (OSHA) to its regional administrators in 1989. The LDEQ report identified radioactivity in produced water and oil equipment which was several times higher than what was permissible by government regulations, while the OSHA memorandum instructed compliance officers to “be aware” for the safety of workers (OSHA, 1989). In 1993, the Society of Petroleum Engineers published a report that stated radioactive contamination, “can be expected at nearly every petroleum facility… maintenance and other personnel may be exposed to hazardous concentrations,” and that scale and sludge wastes “can contain uranium, thorium, radium, and associated decay products” (Gray, 1993).
In 2005 the International Atomic Energy Agency (IAEA) published a report on uranium waste from mining. Page 7 of that report recognized that uranium waste has been widely distributed, and has subsequently deteriorated fisheries, bioaccumulated in plants and animals, and concentrated in aquatic sediments (IAEA, 2005). Five years later the IAEA published a training manual titled, “Radiation Protection and Management of Radioactive Waste in the Oil and Gas Industry.” On pages 127–128, the manual identified and quantified the radioactive waste of the industry (IAEA, 2010)
What kinds of waste are of concern? When wells are drilled and mines are excavated the materials that had filled those cavities are brought to the surface in the form of loose rocks containing uranium, aka tailings. Subsequently, radium-laden water, aka produced water, fills the boreholes and mine shafts, which must also be brought to the surface to ensure the continuation of the extraction process. On page 8 of a report titled, “Radium Content of Oil- and Gas-Field Produced Waters in the Northern Appalachian Basin,” the USGS measured a range of radioactivity in produced waters. The results showed levels of radium in the water, that varied by location, from approximately 1000–5500 picocuries per liter (pCi/L). The report went on to compare those results with drinking water limits of 5 pCi/L and industrial effluent limits of 60 pCi/L. That report also added data to the scientific consensus that a rise in the salinity of produced water is correlated with higher levels of radium (Rowan, Engle, Kirby, and Kraemer, 2011). As these wastes are collected, transported, and disposed of, radionuclides concentrate in equipment and containers. Such waste and its concentrations are classified as Technologically Enhanced Naturally Occurring Radioactive Material, or TENORM (US EPA, 2021(a)).
How are such wastes disposed of or disbursed? The answer to that question is manifold and includes selling the waste as a product and both legal and illegal dumping. In 1971, a New York Times article revealed that uranium mine operators were disposing of uranium waste by allowing builders and residents to use the waste for construction fill in Colorado and Utah (Metzger, 1971). In 2016 Clean Earth Inc. won approval to build a mile-long road in Pennsylvania with 3,950 tons of black shale rock tailings, equivalent to approximately 282 large dump trucks full of black shale rock (Cocklin, 2016). Other disposal methods include spraying produced water on roads to reduce dust or ice (Pohlman and Kuzydym, 2019).
In January 2021, the Colorado Department of Public Health and Environment (CDPHE) enacted regulations for the “beneficial uses” of TENORM. Such uses include land application as a soil conditioner, fertilizer for vegetative growth, and composting. Ironically, the rules state that if TENORM are above a certain radioactive level, operators must erect barriers to public access and utilize signage with the term, “Caution, Radioactive Material.” The rule, aka Part 20, states in section (20.7.1(C)2), that land application cannot exceed 20 years or 20 crop cycles (CDPHE, 2020(a)). However, in a public comment and question section, regarding “Beneficial Use,” an individual asks if splitting a land parcel into four sections will allow for 80 years of TENORM application, to which the CDPHE states “yes,” and reiterates an annual reporting requirement (CDPHE, 2020(b)). Another section of part 20 (20.6.1(E)1) requires the disposal of filter socks in Nuclear Regulatory Commission (NRC) licensed landfills. (CDPHE, 2020(a))
Some disposal methods are less than legal. For example, in 2015 a man was arrested for disposing of filter socks in an abandoned North Dakota gas station (Brown, 2017). Filter socks are filters used to separate solids from flowback water, which is a combination of process and produced water that comes from oil and gas wells. The highly radioactive filter socks have special disposal requirements, but they have been found on the roadside, in trash cans, and on Indigenous reservations throughout North Dakota (McMahon, 2013). North Dakota landfills prohibit TENORM waste that registers over 50 picocuries per gram of solid waste, and they have an annual limit of 25,000 tons of TENORM waste per approved landfill, which can encourage illegal dumping of loads that are rejected for being too radioactive or when the annual quota has been reached (NDDEQ, n.d.). One state that bans radioactive waste, Oregon, recently had 2.5 million pounds of radioactive filter socks dumped in a landfill that is close to the Columbia River (Samayoa, 2020).
Some disposal methods are completely legal and licensed by the EPA. One method is the export of hazardous waste to foreign countries through a comprehensive import/export tracking system (US EPA, n.d.(b)). Another method is utilizing injection wells, which pump fluids from the surface, at high pressure, into underground rock formations. In the 1960’s, when drinking water sources became contaminated from industrial waste being injected into deep wells, the EPA’s precursor, the Federal Water Quality Administration, was given authority to regulate injection wells (US EPA, n.d.(c)). The Underground Injection Control (UIC) Program was established in Subpart D/Part 144 of the 1974 Safe Drinking Water Act (US EPA, n.d.(d)). The EPA has six classes of injection wells in its UIC Program (US EPA, 2015(b)). Class 4 wells are for hazardous and radioactive material and are officially banned. Class 2 wells are strictly for the oil and gas industry. The only fluid that is banned from Class 2 wells is diesel fuel. Otherwise, the industry is free from regulations to pump any of its waste into these wells. There are roughly 180,000 Class 2 wells in operation in the United States (US EPA, 2015(c)).
A third, and pernicious, method uses landfills and sewage treatment plants. This process involves dumping TENORM drilling solids (tailings), and sometimes liquids (produced water), in landfills. When it rains, TENORM liquid leaches through the ground and is directed to a holding area. The liquid (leachate) is collected and taken to public sewage treatment plants for treatment. The “treated” water is then released into waterways, frequently near drinking-water facilities (Public Herald, 2021). Similar processes are being reported by local news reporters and activist groups in several states, including Michigan, Ohio, Pennsylvania, Kentucky, West Virginia, and New York (Gaffney, 2019) (Jackson, 2021) (Matheny, 2018) (Pribanic & Wiener, 2020).
What are the quantities of TENORM waste being produced and/or disposed of? The following examples highlight what is known. In 1999 an USGS report identified highly radioactive oil-field equipment in Texas, Louisiana, Alabama, Mississippi, Illinois, and Florida. The same report showed moderately radioactive equipment in a total of 8 states (USGS, 1999). In the “Background” section of a June 2000 report to the U.S Congress, the EPA estimated an annual production of over 1 billion tons of solid TENORM waste in the U.S. (US EPA, 2000). The New Mexico Environment Department (NMED) reported that, in 2018, New Mexico produced 42 billion gallons of TENORM wastewater (NMED, 2019). The January 2020 Rolling Stone report, by Justin Noble, estimated that 1 trillion gallons of produced wastewater is generated in the U.S. annually (Nobel, 2020). The EPA recently estimated that 2 billion gallons of oil and gas wastewater are injected into the ground daily in the United States (US EPA, 2015(c)).
Discussion
There is radiation everywhere, what’s the big deal? Radiation is a significant problem because some types of radiation cause permanent, life altering damage. For example, there is radiation in the water, the air, even in bananas, carrots, and potatoes (Anticole, 2016). The EPA even has a page that explains the average dose and sources of radiation that Americans receive on an annual basis. The biggest concerns on that page are radiation from medical devices and radon gas from the soil (US EPA, 2015(d)). However, on page 2 of a guide for the removal of radioactive residuals from water treatment equipment, the EPA also recognizes the “significant internal hazards” of alpha and beta radiation from ingestion and inhalation (US EPA, 2005). The EPA’s limit for radium in drinking water is 5 picocuries/liter (US EPA, 2021(b)). The Minnesota Department of Health warns of an elevated risk of cancer from drinking water with radium content above 5 picocuries/liter (MDH, 2019). Meanwhile, radioactive filter socks in North Dakota landfills have been found with radium levels as high as 47 picocuries per gram (McMahon, 2013). In the extreme case of Eben Byers, he was consuming Radithor, which dubiously guaranteed a minimum of 1 million picocuries per half-ounce bottle (ORAU, n.d.).
The reason that radiation from internal sources, such as ingestion and inhalation of radionuclides, is more damaging than external sources, such as x-rays, the sun, and cosmic background radiation, is due to the concept known as Linear Energy Transfer (LET). Online lectures about radiation protection and radiology explain the damage to DNA from LET (ChemSurvival, 2016) (General Radiology, 2021) (World of X-Ray, 2017). Despite being a novice in this field, I will give an abstract of the information.
Gamma rays and x-rays (No-LET) have no mass and no charge, which allows them to bounce through the body and have few interactions with cells. Occasionally, cell interaction occurs, and beta particles are produced. Beta particles (Low-LET) have low mass and charge. Alpha particles (High-LET) are heavier and have greater charge than beta particles, gamma rays, or x-rays. Having a higher mass and charge means that particles travel a shorter distance, in a linear path versus bouncing around, and transfer their energy to every cell in their path. Single-strand-breaks to DNA, are the kind of damage that comes from particles that have lighter mass and charge, which the body can repair. Double-strand-breaks to the DNA, are the kind of damage that particles of greater mass and charge impart to cells, which the body cannot repair. Permanently damaged cells lead to cancer and death. Uranium, thorium, and radium are heavy, charged particles with High-LET. Therefore, there is an increased risk of cancer and death from inhaling or ingesting these particles when they are present in water or dust.
The concept of LET and the danger of internally deposited radionuclides are relevant to the “beneficial uses” of TENORM wastes. When TENORM-laden water is sprayed on roads for dust suppression and deicing it either dries and turns to dust (danger of inhalation) or it is washed into public waterways with rainwater (danger of ingestion). Anyone who has had a mouthful of pool water can recognize the inherent danger of using radium water to treat pools (danger of ingestion) (Pribanic, 2019). For those who are concerned about the condition of their food, water, or environment, few would accept the novel idea of using TENORM water for forest-fire suppression, non-edible crop irrigation, or vehicle washing (danger of inhalation and ingestion) (US DOE, 2020). Few parents would feel comfortable allowing their children to watch a school game from bleachers made with radioactive pipe, as was found in Mississippi (danger of inhalation and ingestion) (OSHA, 1989).
Conclusion
There is incontrovertible evidence of radioactive nuclides being present in the products and waste streams of the oil and gas industry. Congress has passed laws that grant exemptions and loopholes to the industry. The Environmental Protection Agency has proposed and passed regulations that are more concerned with protecting the oil and gas industry than the environment. Courts have often ruled in favor of less regulation of TENORM in the industry (Supreme Court of Ohio, 2018). So, what can be done about it?
Well, here is some good news. If you, the reader, have made it to the end of this report, then you are now informed, and hopefully empowered, to spread this important knowledge. It can take up to ten years for a law to move from Congress, through the regulatory agencies, to being finally tested in the court system. But a movement can spread and grow as fast as the speed of the information that inspired it. So, take this information, share it with another person, and help build a movement of informed citizens and consumers. Most people are unaware of this information, which has been known since 1904. Contact and join activist groups, such as EcoWatch, Food and Water Watch, and the FreshWater Accountability Project. If there are no groups in your area, form one. Listen to and watch the podcasts and documentaries produced by PublicHerald.org. Further reading and investigations into cancer clusters near injection wells, and the contribution of radium to global warming, are warranted. Last, but not least, open a state link below to view maps of injection wells and find what is lurking “Under the Rug,” in your area, or in the area of someone that you love. Knowledge is power!
©2022 Michael Rodriguez
