Radiation Protection

The Marcellus Shale Coalition developed an FAQ document on Naturally Occurring Radioactive Material (NORM) and Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) which is referenced in part below.

What is Naturally Occurring Radioactive Material (NORM)?

NORM is any of the primordial radionuclides or radioactivity present in soils, rocks, and materials, present since the formation of the earth and undisturbed as a result of human activities.

What is Technologically Enhanced Naturally Occurring Radioactive Material (TENORM)?

NORM occurs everywhere in the environment. When NORM is disturbed or altered from natural settings or present in a technologically enhanced state due to past or present human activities and practices, the material is known as TENORM. “Technologically enhanced” refers to a relative increase in radionuclide concentrations above background radiation levels as a result of changes to the radiological, physical, and chemical properties of the radioactive material. In comparing background radioactivity or radiation levels with TENORM, the definition does not provide a point of reference, such as a level equivalent to a multiple of background, because this could lead to situations in which a material not considered TENORM in a high-background area could become TENORM when relocated to a lower-background area. TENORM does not include radiation emanating from or radioactivity present in ores, rocks, soils, and materials containing uranium and thorium subject to regulations under the Atomic Energy Act (ANSI/HPS N13.53-2009).

How are NORM and TENORM Associated with Shale Oil and Gas Formations?

Naturally occurring radionuclides and their decay products are associated with various natural formations, including shale rock and oil and gas formations, because of the origin of these sedimentary rocks and their organic content. According to the United States Environmental Protection Agency, much of petroleum and natural gas developed in the U.S. was created by the decay of ancient sea life. Oil and gas deposits often occur in aquifers containing brine (salt water). NORM and other dissolved minerals in the brine form various wastes when brought to the ground surface, including sludges/sediments and produced water (water extracted from the gas). These wastes are classified as TENORM because the extraction process concentrates the NORM.

Read the Marcellus Shale FAQ document on NORM and TENORM

What is the range of typical radiation dose from exposures to typical NORM and TENORM sources?

Average annual radiation dosage chart, Click to enlarge

To contextualize, CNX presents several potential sources of NORM and TENORM exposure and the estimated annual dose associated with each source. The radiation dose is expressed as millirems (mrems), which is a common unit utilized to quantify the amount of radiation absorbed by the body. The Nuclear Regulatory Commission (NRC) maintains a personal annual radiation dose calculator available here.

According to the NRC, the average American receives a dose of about 620 mrems each year from a combination of natural and man-made sources of radiation. The graphic above provides a summary of estimates of radiation dose associated with various activities. In any given setting, the actual doses are expected to vary somewhat from the precise estimates provided. Even so, we can assume that the annual radiation dose resulting from driving a shale oil and gas wastewater truck is likely to be less than 1 mrem, or less than one-tenth of the dose from a single chest X-ray. Similarly, the annual radiation exposure to workers at a shale oil and gas well site is expected to be less than 30 mrems, or about one quarter of the expected annual dose experienced by a resident of Albuquerque.

What is CNX doing to monitor the risks from TENORM?

A comprehensive study performed in 2014 by the Pennsylvania Department of Environmental Protection (PA DEP) in cooperation with other public and private organizations, determined that NORM and TENORM materials associated with the oil and gas Industry are well managed and do not present a risk to the public. The oil and gas industry characterizes and profiles waste materials for ultimate disposal at appropriate permitted facilities. Further, while the majority of waste streams generated by the oil and gas industry do not pose a risk to workers or the general public, CNX makes proper adjustments to handling, processing, and disposal protocols based on screening, monitoring, and analytical data.

CNX employs personnel who are trained on NORM protection, proper handling and proper disposal of NORM and TENORM containing waste. All potential NORM exposures to workers and members of the public from TENORM are either eliminated or reduced to levels that are well below acceptable radiation protection standards. CNX ensures protection by following the CNX Comprehensive Radiation Protection Plan (CRPP), in conformance with 25 PA Code 293.111 requirements. It has been developed to provide guidance for radiological monitoring, safety protocols and procedures, and regulatory requirements to personnel working at CNX locations.The scientific consensus is that there is “little potential for significant radiological exposure to workers and members of the general public related to E&P operations” (PADEP 2015), but even so, our Radical Transparency program will help to allay any remaining concerns.

The CRPP identifies potential sources of radiation across the drilling, fracturing, producing, water and waste operations of CNX. It details the type of monitoring needed to identify potential sources of radiation, steps to keep worker exposure as low as reasonably achievable (ALARA), proper handling, as well as transportation and disposal of each potentially radioactive waste stream generated throughout CNX operations.

The intent of this CRPP is to provide a common-sense graded approach to radiation hazards identification and mitigation. The CRPP outlines CNX’s approach to: 

  • Sampling waste and determining radionuclide levels, using these to ensure proper protection and disposal; (in addition, our enhanced groundwater monitoring activities will also lend themselves to ensuring protections on the radionuclide front)
  • Monitoring truckloads of waste when it leaves the well site and when it arrives at a landfill to ensure community protection; 
  • Performing work area surveys to determine radiation exposure levels; 
  • When necessary, performing contamination surveys of personnel and equipment prior to leaving work areas; and
  • Preparing and implementing a radiation action plan if required.

CNX has increased the frequency of monitoring activities which were previously reviewed quarterly and are now reviewed and recorded monthly.

CNX’s monitoring activities are scheduled to occur at the below locations and frequencies:

Facility Radiation/Contamination Monitoring Gamma Survey Alpha/Beta Swipe Survey Particulate Air Sampling Radon Air Sampling Survey Frequency Comments
Active Drilling Site (survey a different facility each time) X X     Monthly Perform gamma surveys of tanks and process equipment. Take/analyze 10 swipes of process equipment.
Active Completions Sites (survey a different facility each time) X X     Monthly Perform gamma surveys of nuclear density gauges, tanks and process equipment. Take/analyze 10 swipes of process equipment (inside gas busters or accessible system internals).
Wells in Production (survey a different facility each time) X       Monthly Perform radon baseline air sampling. Perform alpha, beta and gamma surveys of process equipment quarterly and upon system breach when performing maintenance and/or pigging. Survey pigging equipment, work area and waste containers.
Midstream Compressor Stations (survey a different facility each time) X X   X Monthly Perform radon baseline air sampling. Perform alpha, beta and gamma surveys of process equipment quarterly and upon system breach when performing maintenance and/or pigging. Survey pigging equipment, work area and waste containers.
Wastewater Storage (survey a different facility each time) X X X   Monthly Perform gamma surveys around perimeter and on waste containers. Perform boundary air sampling of impoundment ponds to determine concentration of particulate airborne radioactivity.
Equipment Storage Facilities (survey a different facility each time) X X     Monthly Perform alpha/beta and gamma surveys on legacy equipment to establish baseline conditions. Survey potentially contaminated equipment when accepted for storage and prior to sending to a landfill or recycling facility.
Abandon Well Plugging (survey a different location each time) X X     Monthly Survey piping and equipment that will be recycled. The release limit to pipe machine shops/re-work facilities is <1000 dpm/100cm2 removable beta unless they are properly permitted. Release to recycle melting facilities is 50 uR/hr.
Radiography X       Monthly Verify contractor area evacuation and posting procedures. Verify radiography boundaries do not exceed 5 mRem/hr.
Transportation Surveys X X     Per container Periodic gamma survey of inbound waste containers. Gamma dose rate survey of outgoing waste containers prior to transportation. This is in addition to any required testing at the receiving waste disposal location.

CNX is committed to disclosing the findings associated with the monitoring we conduct as part of our overarching CRPP. We will disclose these findings and any actions that may result from encountering any unanticipated TENORM levels associated with our operations. 

Read CNX's Comprehensive Radiation Protection Plan
Read CNX's Comprehensive Radiation Protection Plan Annual Self-Assessment

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